Embed Size (px)
Citation preview
Your ref WS010003 ARROW ref 10024954 Nicola Escott ref 10024302 ARROW 1 - Responses to the Examining Authority’s First
Written Questions and Requests for Information by
Alan Watson (Public Interest Consultants)
Incomplete Application Documents:
1. It is important to introduce this submission by noting our concerns about the application documents still being incomplete.
2. The minutes of the preliminary meeting (p8) record:
“Alan Watson for ARROW (AW) submitted that some documents (such as the hydro-‐‑geological risk assessment) were incomplete.
….
WML noted that the hydro-‐‑geological risk assessment was not in final form and would be submitted.
….
They would produce a core documents list with their cited documents, where they were available”.
3. The full discussion at the preliminary meeting went further and WML promised to provide a copy of the Environmental Permit Application (which was said to include more recent documents than those in the planning application).
4. Following this promise by WML we expected copies of the latest reports, the core documents list and copies of the documents relied upon by WML to be provided soon after the preliminary meeting. As they did not materialise ARROW has sent a number of reminders about this via PINS yet there has still been no progress in relation to the supply of any final hydrogeological risk assessment nor of any core document list with documents relied upon by the applicant in the application.
5. As a last resort ARROW tried to obtain a copy of the Environmental Permit Application directly from the Environment Agency. Unfortunately the application is not yet available on the public register as it was only submitted after the preliminary meeting and has not yet been registered as being “duly made”. The Environment Agency is unable to provide copies of the documents they have received until the application is accepted as being “duly made”.
6. It is understood that the Environment Agency had expected that the application
ARROW 1
2
would have been submitted in late 2013 so that the application could be effectively run in parallel with the planning application as recommended by PPS10(§28). There is now a real concern that the applicant is attempting to leave many of the issues in the application to the Environmental Permit when they are actually requirements of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (as amended). The consequence of the failure of the applicant to provide the final documents that were promised are that the application fails to meet the requirements of the Environmental Assessment Regulations.
7. Furthermore it is noted that Schedule 25, Part 2, paragraph 4(2) to the Environmental Permitting (England and Wales) Regulations 2010 SI 2010 No. 675 places a specific responsibility on Waste Planning Authorities (including PINS/the SoS in this case) to consider the requirements of Annex 1, paragraph 1.1 to the Landfill Directive when considering whether or not to grant planning permission for a landfill.
8. These requirements are those which were listed in the Landfill Regulations 2002: the distances from residential and recreational areas; the proximity to water sources; geological and hydro-‐‑geological conditions; the risk of natural disasters; and protection of the site’s heritage.
9. In this case the application is deficient in relation to the information needed to properly consider all these issues – most obviously in relation to the Hydrogeological Risk Assessment (HRA) which is currently only provided in an incomplete preliminary draft form dated December 2013. As the documents promised by WML have not been provided ARROW has not yet been able to prepare a response on issues which may be affected by them. This obviously includes, but is not limited to, the geological and hydro-‐‑geological matters. A range of other issues are affected because ARROW does not have the resources to retain consultants to review and respond to documents which are not final or complete and face the risk that the issues may have to be re-‐‑visited at additional expense when new information becomes available.
10. The present responses therefore include answers to questions put specifically to ARROW together with submissions on health concerns and perception of risk. We will certainly want to respond in detail to other issues, including ground water and hydrogeological matters, when we have access to the complete and final application documents.
11. Assuming the missing documents and Environmental Permit application are now provided promptly the response by ARROW on the remaining issues will now have to be made by the 8th July deadline.
ARROW 1
3
Responses to the Examining Authority’s First Written Questions and Requests for Information
12. This section of the report responds to specific questions about which ARROW was asked to comment.
Input Rates
13. In s.3.4 the Applicant, EA, LCC; WLBC; ARROW were asked:
Chapter 3 of the ES sets out the proposed maximum input rates to the landfill void (150,000 tonnes per annum (tpa)). If these input rates are achieved, they would secure the filling/restoration of the site by the end of the permitted period.
a) How do these input rates compare with the rates which have been achieved historically at the site?
b) Can evidence be provided of the likely source and quantities of the hazardous waste arisings which would be deposited at this site in order to demonstrate the actual input levels likely to be achieved?
c) To what extent could the hazardous waste arisings identified in b. be processed in alternative facilities which are geographically closer to the source of the arisings or which are at a higher level in the waste hierarchy than landfill?
d) In the event that the input rates are not achieved, what would be the implications for the restoration of the site at the end of the permitted period?
e) Would any potential changes to input rates fall within the parameters assessed in the ES?
14. Addressing these points in turn:
a) How do these input rates compare with the rates which have been achieved historically at the site?
15. The full information needed to answer this question is difficult to obtain as is probably only available to the applicant. The Environment Agency public register should provide sufficient information to address the question for these purposes but when it was inspected to collect information to respond to this application it was found to be seriously incomplete and much of the information required by the Regulations to be provided to the public was not readily available. The Environment Agency staff were helpful and apologetic about this explaining that the public registers are not frequently visited and so their regular upkeep has not been a high priority. A request has been made to the Environment Agency for copies of the missing data but this has not yet arrived. If it is supplied in time for the next tranche of responses then this submission will be updated.
ARROW 1
4
16. The information on the Environment Agency public register on operator declared site inputs since 2012 is:
Year Quarter Input Tonnes Remaining Void M3 2014 1 11,965.75 51,048 2013 4 11,154.96 57,196 2013 3 23,870.68 64,172 2013 2 32,668.60 57,650 2013 1 8,316 68,500 2012 4 4,438.97 73,610 2012 3 4,570.72 81,055 2012 2 8,061.96 84,087 2012 1 19,717.72 99,587
17. The total inputs claimed for 2013 were 76,009 tonnes and for 2012 inputs were 36,789 tonnes. It can be seen that for the majority of the time the site inputs have been very low and only in the second and third quarters of 2013 was there any activity which approached the projected input rate in the application. This was a short burst, however, and has never been maintained over a longer period of time.
18. Furthermore there is clearly some anomalous reporting of the remaining void space – most notably for the 3rd Quarter of 2013 where the claimed remaining void space increases in spite of higher rates of input into the site. The site input and voidspace figures cannot both be correct and a reply is awaited from the Environment Agency for an explanation of these data.
19. The PEIR (§4.4) and the ES (§4.2.1) claim “Although landfilling is permitted at the site until 2018 due to the current hazardous waste input rates it is anticipated that the current landfill area will be filled by the end of 2015”.
20. This claim seems unlikely to be achieved in practice and the latest operator report for the end of the first quarter of 2014 indicated that the site still had 4.75 years remaining capacity.
21. Other information just supplied by the Environment Agency from their national data base indicates that the input rates were slightly higher for 2013, the reasons for the difference are unclear and an explanation is being sought from the Environment Agency.
Year Input Treatment
2013 88,008.8 261.2
2012 37,183.69 842.5
2011 27,047.78 849.27
2010 26,752.75
2009 26,388.76
2008 35,917.96
ARROW 1
5
22. Even with the higher input rates for 2013, however, the site averaged only just over 40,000 tpa over the period from 2008 to 2013 and had a maximum input of less than 60% of the fill rate that must be averaged through to 2035 if the completion date in the application is to be met.
23. The interceptor treatment facility input rates are also very low compared with the application rate of 20,000 tpa. The Environment Agency data shows that the annual inputs have not exceeded 5% of this rate.
b) Can evidence be provided of the likely source and quantities of the hazardous waste arisings which would be deposited at this site in order to demonstrate the actual input levels likely to be achieved?
24. Again we are largely reliant on the applicant to provide information in support of their case as the application currently contains credible indication of sources of waste to justify an enormous increase in throughput over a long period of time.
25. The applicant faces two fundamental problems in attempting to promote additional waste disposal by landfill at the bottom of the waste hierarchy:
i) the total arisings of hazardous waste arising are falling
ii) demand for hazardous waste landfill is reducing as the hazardous wastes which are still being produced are increasingly recovered or treated by other more sustainable and environmentally sound options higher up the waste hierarchy
26. The most recent Environment Agency summary data1 covers the period to 2012 and clearly shows these trends in hazardous waste arisings over the period since 2000 -‐‑ and particularly how steeply the demand for hazardous waste landfill has fallen:
1 http://webarchive.nationalarchives.gov.uk/20140328084622/http://cdn.environment-‐‑agency.gov.uk/lit8765_794dfc.pdf
ARROW 1
6
27. The summary also shows that only about 20% of hazardous waste arisings
were landfilled in 2012:
28. Data published by the Environment Agency and included in the responses to
the Section 47 consultation (See Appendix CONSAQ pp1-‐‑11) has been updated to include the 2012 Figures2.
29. The more recent data shows that Lancashire continues to be a significant net importer of hazardous waste importer of wastes from outside the North-‐‑West region with imports exceeding exports by 13,567 tonnes. For the North-‐‑West region imports exceeded exports by 214,874 tonnes:
2 http://webarchive.nationalarchives.gov.uk/20140328084622/http://www.environment-agency.gov.uk/research/library/data/150326.aspx
ARROW 1
7
30. In 2011 69,542 tonnes of Hazardous waste was landfilled in the North-‐‑West
and this fell to just 54,955 tonnes in 2012:
31. The claimed 150,000 tpa input is equivalent to Whitemoss capturing more
waste than the entire market for the North-‐‑West AND the Yorkshire and the Humber. That is completely implausible given the number of operational sites and the high level of competion:
32. The Environment Agency did not update the figures for landfill capacity in
2012 but they confirm that voidspace has been used for 78,000 tonnes of landfilled waste. Assuming an average density of 1.5 tonnes/m3 3 then the 2011 void space would be depleted by c.52,000 m3. This would leave the landfill capacity in the North West for merchant hazardous waste sites at around 5,000,000 m3 made up of c.1,800,000 m3 at Minosus in Cheshire, 3,100,000 m3 at Randle Island in Merseyside and just less than 1,000,000 m3 at White moss in Lancashire. This is sufficient landfill capacity for more than 7.5 million tonnes of hazardous waste. On top of this are landfill sites in Lancashire, Greater Manchester and Cumbria with large cells for Stable Non-‐‑Reactive Hazardous Wastes.
3 this is likely to be conservative as many hazardous wastes have a higher density than this – glass from CRT tubes, for example, has a density of c.3 tonnes/m3 and a mixture typical of a C&D waste would be c.2 tonnes/m3
ARROW 1
8
33. Together this represents an enormous landbank representing about 100 years supply at current rates of usage.
34. It is suggested by the applicant that the Randle site is really a restricted site annual. This is clearly incorrect and Ineos advertises the site as being “Strategically located to serve all areas of the North West” from which it is able “to receive a wide range of hazardous waste materials” and notes that the site is “fully permitted to Pollution Prevention and Control Regulations”4.
35. It is also suggested by the applicant that the Randle site needs to be dedicated to the disposal of residues from the Runcorn incinerator. This is not correct. The Runcorn Energy from Waste Facility operated by Ineos has a maximum capacity of 850,000 tonnes per annum and as only the air pollution control residues are normally treated as hazardous wastes by the Environment Agency this is likely to account for no more than 25,000 tonnes of the annual capacity. This leaves generous provision for the rest of the North-‐‑West landfill needs within an annual limit of 150,000 tonnes. It should be noted that both the Randle and Minosus sites can receive incinerator residues.
36. Whilst there is already more than sufficient hazardous waste capacity it is also important to recognise that the trend for landfill disposal of hazardous waste has been a steep fall since the early part of the last decade when an average of 284,000 tonnes per annum were landfilled in the North-‐‑West with a maximum of 392,308 tonnes in 2004. In 2011 the tonnage was less than 70,000 tonnes and this fell to under 55,000 tonnes in 2012. The average tonnage disposed to over the period since 2008 has been only just over 70,000 tonnes – about 25% of the average landfilled tonnage from five years earlier. It is perhaps not surprising, therefore, that when considering England and Wales as a whole, there are consistently large net movements of hazardous waste into the North-‐‑ West in 2012 with the Region handling 716,463 tonnes of wastes (16.2% of the UK total) but with arisings of 495,373 (11.6% of the UK total):
37. It is also striking that more than 30% of the hazardous waste landfill capacity
4 http://www.ineos.com/businesses/ineos-chlorvinyls/products/
ARROW 1
9
in England and Wales is already sited in the North-‐‑West – more than any other region apart from the neighbouring North-‐‑East with 43.3%5:
38. With >73% of the landfill capacity in the north of the country sensible spatial
distribution requires that provision of new capacity should be outside these regions and in those areas with much lower capacity .
39. It is correct that the White moss permit covers a larger number of European waste categories (230) than the alternative, much larger, sites in the Region. The permit for Randle covers 144 waste categories and the Minosus Permit includes 42 waste categories. Whitemoss does not, however, landfill wastes from the majority of these categories. The information available indicates that the site uses less than 25% of the permitted categories and around 80% of the waste landfilled falls within about 3% of the permitted categories. In 2012, for example, c.82% of the site inputs fell within just 7 waste codes: Arising from: EWC_Code ShortClass Tonnage % input
North West 170503 soil and stones containing dangerous substances
17468.42 48.9%
North West 101111 waste glass in small particles and glass powder containing heavy metals (for example from cathode ray tubes)
4020.54 11.2%
West Midlands 170503 soil and stones containing dangerous substances
2767.19 7.7%
North West 170605 construction materials containing asbestos
1606.35 4.5%
Yorks & Humber 190813 sludges containing dangerous substances from other treatment of industrial waste water
1242.16 3.5%
North West 170301 bituminous mixtures containing coal tar
1099.5 3.1%
North West 170106 mixtures of, or separate fractions of concrete, bricks, tiles and ceramics containing dangerous substances
970.04 2.7%
40. It can be seen from the full input data that more than 80% of the site input
5 This is based on Environment Agency data from 2011 as that is the last year for which it is available.
ARROW 1
10
comes from the North-‐‑West.
41. Furthermore the waste groups for Randle and Minosus are so widely defined that together they cover all the significant waste streams landfilled at White moss. At the recent Lancashire EIP neither the joint Authorities nor the applicant could cite a single waste stream which was landfilled at Whitemoss but which could not be landfilled at other sites in the North-‐‑West.
42. More than 70% of the waste input to Whitemoss is EWC category 17 construction waste. The applicant suggests that the explanation for the low levels of inputs to the site are due to the recession and the associated fall in waste arising.
43. The applicant says, for example6:
“While the amount of waste disposed of at Whitemoss has reduced recently when compared to previous years, this is explained by the recession and reduced activity in the construction industry”.
44. Optimistically (from the applicants perspective) they continued:
“This situation can be expected to change. As the economy recovers, the hazardous waste inputs are expected to increase”.
45. There is no evidence in the application to support this hypothesis and it certainly does not stand closer scrutiny. When the arisings of C&D waste and asbestos for the North-‐‑West are plotted it can be seen that they peaked in 2004 – pre-‐‑dating the recession and the only year when arisings exceeded 150,000 tpa -‐‑ and have steadily fallen since. This is much more likely to reflect the steady increase in the use alternative solutions such as bio-‐‑remediation, in-‐‑situ and ex-‐‑situ treatments reflecting the higher costs of the outmoded “dig and dump” approach:
6 Appendix CONSC §10 p3 of the submission to the “JOINT LANCASHIRE MINERALS & WASTE DEVELOPMENT FRAMEWORK (SUBMITTED SITE ALLOCATIONS AND DEVELOPMENT MANAGEMENT POLICIES DPD) POLICY LF3 - LAND AT WHITEMOSS LANDFILL, SKELMERSDALE”
ARROW 1
11
46. The national picture also shows that C&D waste peaked in 2004 and has
plummeted since. There is also a steady increase in ex-‐‑situ treatment capacity for these wastes:
47. It is notable that in 2013 the Secretary of State approved a Development
Consent Order for the East Northamptonshire Resource Management Facility (ENRMF) at Kings Cliffe, Northamptonshire. That was also for 150,000 tpa capacity but it included an extension of the soil treatment facility from 100,000 to 150,000 tpa thus helping to move waste up the hierarchy. Furthermore the landfill had received an average of 132,000 tpa of waste since 2005.
48. Similarly Peel Environmental is currently proposing to develop a hazardous waste management facility at Perry’s Farm on The Isle of Grain, Kent. That proposal also includes a contaminated and hazardous soil treatment and recycling centre, air pollution control treatment and disposal, and landfill. The facility will process in the order of 150,000 tonnes of waste per year. This offers a much wider range of treatment options above disposal in the waste hierarchy than are proposed by Whitemoss and, like Kings Cliffe is significantly closer to major sources arisings in an area with much less comprehensive coverage than
ARROW 1
12
the North of England. Work is proposed to start on the site in late 2015 and the proposed operational period is from 2016 until 2046.
49. Conclusion
50. The most recent Environment Agency data therefore confirms the previous conclusions that Lancashire already makes disproportionately large provision for the treatment of hazardous wastes and that provision of additional landfill capacity is both unnecessary and would be likely to undermine the waste hierarchy.
51. There is more than sufficient additional hazardous waste landfill capacity in the North-‐‑West. The arguments about limited waste types and mistaken claims by the applicant about Randle Island Landfill being a restricted site are red herrings. When challenged at the recent EIP neither the Joint Authorities nor the applicant were able to identify any actual waste arisings which are (or could be) landfilled at White moss but not treated elsewhere in the North-‐‑West. In most cases the alternative sites would probably also be more proximate to the actual arisings consistently with the proximity requirements of Article 16(3) of Directive 2008/98/EC on waste.
52. No extension to Whitemoss Landfill is needed for Lancashire, the North-‐‑West or for England and Wales. Additional provision in these circumstances undermines the waste hierarchy, increases the distance waste travels, unreasonably extends completion periods and the time for which sites blight their neighbours. This is not sustainable and would not be consistent with the NPPF.
c) To what extent could the hazardous waste arisings identified in b. be processed in alternative facilities which are geographically closer to the source of the arisings or which are at a higher level in the waste hierarchy than landfill?
53. This should have been included in the application as the Environmental Assessment regulations require the applicant to produce an outline of the main alternatives studied by the applicant and an indication of the main reasons for the applicant’s choice, taking into account the environmental, social and economic effects. This has only been done in the most superficial way in this case. No consideration was given, for example, to the fact that due to the restoration conditions on the current site it should be assessed in planning terms as a greenfield site. Yet it is only due to the existing site, which was never originally planner or intended as a hazardous waste site in any case, that the extension is now proposed.
54. We will address this when question in detail when the applicant have indicated what source they rely on for their projected capacity.
d) In the event that the input rates are not achieved, what would be the
ARROW 1
13
implications for the restoration of the site at the end of the permitted period?
55. The current site has required a total of eight extensions to the planning permission as a result of over-‐‑optimism by the applicant about the rate at which it could be completed. The enormous capacity of the proposed extension and the reduction in waste arisings mean that it is quite possible that the extension might never be capped and completed. This would leave the site as an enormous environmental liability with different consequences depending on how much waste was in place. With limited waste inputs then avoiding basal heave and the lifting of the liner by external groundwater could be difficult; at a later stage, as drainage could not be secured by capping there would be increased difficulties in maintaining an inward hydraulic gradient from groundwater to the site. As the leachate levels rose the hydraulic flow would reverse and leachate would flow through the liner and directly into groundwater.
e) Would any potential changes to input rates fall within the parameters assessed in the ES?
56. This seems unlikely as the ES does not address the implications of differing input rates or any completion date other than 2035.
ARROW 1
14
58. General Amenity
59. ARROW was specifically requested to respond to four questions (3.26-‐‑ 3.29) under the heading of General Amenity. The answers to these questions are included in this section.
60. In s.3.26 West Lancashire Borough Council (WLBC), LCC, St Helens Council (SHC), EA, IPs, ARROW and the Applicant were asked:
The applicant has carried out a quantitative assessment of the potential effects of odour. However, the subjective nature of this approach can increase difficultly in determining the validity of the assessment conclusions. Has the applicant’s approach been agreed with relevant consultees? Is there any more objective methodology which might be applied to the assessment of odour impacts at the application site?
61. It is not clear why it is considered that the approach adopted by the applicant represents a quantitative assessment of potential odour effects. The ES says (§19.2.3) “ The assessment of the effects has been prepared based on a qualitative assessment of the likely impacts and any specific comments raised during the pre-‐‑application consultation” (my emphasis). It is hoped that the Environmental Permit will include a quantitative assessment as the ES says (§21.4) “ The assessment of the effects has been prepared based on a qualitative assessment of the likely impacts and any specific comments raised during the pre-‐‑application consultation.” When a copy of the quantitative assessment included in the Environmental Permit application has been provided we will review it and submit our further comments. It is certainly possible to assess the likely presence of odorous volatile organic compounds (VOC) in the waste stream and assess their concentrations both on and off the site in terms of odour thresholds. Dincer et al (2006)7 for example found a statistically significant linear relationship was found between odour concentrations determined by olfactometry and total VOC concentrations. They also examined the relationships of odour concentrations with the different groups of chemicals using a multiple regression analysis and found that the concentrations of aldehydes, ketones, and esters are the best estimators, explaining 96% of the variability in odour concentrations. We hope that the Environmental Permit application contains a quantitative approach of this type based on on-‐‑site analysis of VOCs.
62. In s3.27 WLBC, LCC, SHC, EA, IPs, ARROW and the Applicant were asked:
63. What evidence is there to support the applicant’s argument that hazardous waste does not produce significant odorous emissions (ES Paragraph 19.4.5)?
7 Dincer, Faruk, Mustafa Odabasi, and Aysen Muezzinoglu. 2006. Chemical characterization of odorous gases at a landfill site by gas chromatography–mass spectrometry. J Chromatogr A 1122 (1–2): 222-‐‑229.
ARROW 1
15
What controls could be put in place to ensure that the site does not receive waste which is potentially odorous?
64. The applicant clearly accepts that hazardous landfill sites can produce odours – and the five enforcement notices and the successful prosecution of the operator by the Environment Agency show that odours have arisen from the site in the past. At the time of the majority of the odour problems the operators consistently denied any responsibility for the generation of these odours. The applicant now accepts, however, (ES§16.3.8) that “four of the five air pollution incidents relate to landfill odours and one relates to chemical odour”. They say that the landfill odour “related to operational issues at the site which were addressed at the time”. The previous refusal of the operator to accept any responsibility for the odours, particularly at the time in 2005-‐‑6 has left a legacy of mistrust with the residents around the site who were so badly affected by these incidents. Furthermore residents remain convinced that more recent odour problems are related to the site (see ES §19.3.3) are related to operations at the site but that the operators are following the same approach to denial that they now de facto admit they adopted previously.
65. Many of the wastes categories included in the permit are potentially odourous and the applicant accepts (ES§19.4.5) that “Odour emissions may be generated from the importation and landfilling of odorous wastes”. It is correct that if the inputs of putrescible material are minimised then the generation of methane can be limited. This certainly does not mean, however, that “it is unlikely that significant odorous emissions would be generated from imported wastes”.
66. Over 300 trace compounds have been identified in gases from landfill sites. The unpleasant odours are usually associated mainly with the sulphur-‐‑containing compounds, primarily mercaptans and sulphides but also alkylbenzenes, limonene and certain esters. The vast range of trace compounds measured in LFG is a reflection of both the anaerobic decomposition processes taking place in the waste mass and the wide range of chemicals introduced in the waste streams. These compounds can be found in several of the major waste streams for which the site is permitted – not least because the waste categories in the permit are often very wide and allow huge range of contaminants in soil, for example. These can then generate odourous compounds through anaerobic processes so ensuring that no putrescible wastes were allowed on the site along with much more effective analysis of site inputs should help to reduce emissions but they are very hard to eliminate completely from mixed waste landfills.
67. In s3.28 WLBC, LCC, SHC, EA, IPs, ARROW and the Applicant were asked:
reference is made in relevant representations to complaints of odour from the site. What is the history of odour complaints relating to the application site, and what evidence is available to demonstrate that the odour emanated
ARROW 1
16
from the operation of the existing landfill site? Are there other potential sources of odour within the vicinity of the site?
68. The odours from the site are particularly distinctive and unlike those from, for example, the spreading of sewage sludge. Many residents have come to recognise the characteristics of the sites odours from their own experience and then comparing it to the smells that are undeniably coming from the site such as can be picked up from time to time along the adjacent footpath or roadway. There was certainly more regular and more powerful odour nuisance from the site in the middle or the last decade than there has been since but the reality is that many residents have become disillusioned with the response that they have received from either the Environment Agency or the Environmental Health department and have simply stopped complaining. It is hoped that residents will speak to their own experience of odours at the open sessions.
69. In s.3.29 WLBC, LCC, SHC, EA, IPs, ARROW and the Applicant were asked:
70. To what extent is the existing gas management system effective in minimising or eliminating significant odour impacts? Would the existing gas flare stay in its current position; would its use be extended beyond 2020, and how far is the gas flare from the nearest residential property? Where would any future gas flares be located and what would be the distance between any future gas flares and existing properties?
71. We sought information from the Environment Agency about analysis of the gas from the site and emissions from the flare to assess the effectiveness of the flare at destroying odorous compounds. Whilst this information should have been on the public register we found that it was not. We will therefore respond more fully when the data we have requested is supplied by the Environment Agency.
