Herts. WithOut Waste (HertsWOW)

Recycling and composting not disposal


EA's Consultation on the draft Environmental Permit

Posted by hertswow on September 26, 2018 at 4:10 AM

We have made a submission to this Consultation, as follows.


We draw attention to matters within the scope of those identified in paragraph 4.1.4, Key Issues in the Determination, page 16: “… assessment of air quality, assessment of health effects, assessment of noise impacts, assessment of BAT and consideration of consultation responses, …”:

Temperature inversions: The CALPUFF software module is used for modelling in several case

studies. We raised queries about the potential for higher pollution levels.

Local emission sources: We noted these potentially expanding or new sources that should in our

view be taken into account in the assessment of cumulative impacts: Pharmaron UK Limited

and Woollensbrook Crematorium.

Water discharge: We noted the constraints on discharges of secondary treated domestic sewage

to water bodies, in this case to the River Lee, and asked for evidence of compliance by the


Long term emissions of oxides of nitrogen: We asked the EA to explain the relatively high

emissions estimated for the proposed facility at Rye House, Hoddesdon, in comparison with

other incinerator facilities.

Best Available Technicues for this installation: We enquired whether there are specific features (other than site-specific features) of the proposed installation in regard to BAT.

Period of abnormal operation: We raised queries about the way in which the end of the period of

abnormal operation would be determined.

Health impacts of emissions by industrial processes: We noted recently published research

findings and asked for the EA to suggest to HMG that it is time to review the current guidance.

Our detailed response is available on request and will be published shortly on the EA's new online consultation hub, Citizen Space: https://consult.environment-agency.gov.uk/psc/en11-0rf-veolia-es-hertfordshire/" target="_blank" rel="nofollow">link.


Responses are listed by response number. You can use the Search box to find a particularsubmission

Responses whose the senders have allowed to be published may still be redacted for personal identities.

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