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Mr Tony Jarvis

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Mr Tony Jarvis Mr Tony Jarvis - Head of Thermal Power Our ref: NO/2012/103343/01-L01 Projects Your ref: 111108 Centrica Plc Millstream Maidenhead Road Date: 29 March 2012 Windsor Berkshire SL4 5GD Dear Mr Jarvis ROOSECOTE BIOMASS POWER STATION, SECTION 42 CONSULTATION ROOSECOTE POWER STATION IN BARROW IN FURNESS Thank you for referring the Section 43 Consultation on the above proposals, which we received on the 16 February 2012. We have the following comments to make. Flood Risk There are areas within the application site such as parts of the rail link which are located within the indicative tidal flood plain, the area of which is based on the approximate extent of floods with a 0.5% annual probability of occurrence. Hydrology and Flood Risk has been covered within the Preliminary Environmental Information (Ref OXF7339) dated February 2012. We recommend that the sequential approach be undertaken, where practicable, within an application boundary. This ensures that the more vulnerable parts of a development are sited in areas at least flood risk. It is understood that this approach is being used within the site for example with the fuel handling facilities which are located in flood zone 1. Section 7.7.2 states that the rail route is typically between 6.3 and 6.5m AOD. Section 7.9.8 states that the proposed rail route would be flooded to a depth of around 100mm during a 1 in 200 year event based on tidal data provided. However this does not appear to include an allowance for climate change and freeboard. The applicant should be aware that the tidal levels that we provide are based on astronomical tides approximately 2km off the coastline and do not take into account wave action / tidal surge. Therefore the potential flood depth in an actual 1 in 200 year event could be higher than the 100mm depth quoted. We recommend that applicants add freeboard of 600mm to design flood levels together with an allowance Environment Agency Ghyll Mount (Gillan Way) Penrith 40 Business Park, Penrith, Cumbria, CA11 9BP. Customer services line: 03708 506 506 www.environment-agency.gov.uk Cont/d.. for climate change. However, we are aware that ,due to the need for the proposed rail line to tie-in with the existing line, any significant raising of levels for the line may not be practicable. The applicant should ensure that as a result of the proposals flood risk is not increased elsewhere. To this end the applicant has outlined some mitigation measures such as potential compensatory storage. Further modelling should be able to identify the need for such requirements. On sites above 1 hectare the applicant should seek to reduce flood risks associated with surface water run-off. Section 7.9.11 outlines opportunities to reduce flood risks associated with surface water and sewer flooding. We recommend the use of appropriate Sustainable Drainage Systems (SuDS) where practicable to control surface water as close to source as possible and improve water quality. If any discharge is proposed to a receiving watercourse it should be limited to greenfield run-off rates or less. The applicant should consider the flood risks associated with both the construction and the final design and the footprint of any buildings should be sited in flood zone 1 where practicable. Plant, materials and compound facilities should be stored in flood zone 1 where practicable. Low Level Beck and Poaka Beck are designated Main Rivers and as such any works in, over, under or within 8m of the top of bank requires Flood Defence Consent from ourselves. Flood Defence Consent is also required for works within 8m of a tidal defence. At this stage it appears that the conveyor, rail line and other elements of the proposals may require such consent. Any works which affects the flow of a non-main river also requires consent. The applicant should be aware that it takes a period of up to 2 months to determine a valid consent application. We are aware that there are several options being considered by the applicant including extension of the quay, 3 storage silos etc. The applicant should ensure that the requirements of National Planning Policy Framework Section 10 are satisfied along with Technical Guidance to the National Planning Policy Framework. All proposals must be designed to be safe from flooding whilst not increasing the flood risk elsewhere. From the details provided it appears that the flood risks at this location can be mitigated against during the design stage and with the provision of a satisfactory Flood Risk Assessment. Therefore we do not foresee any objection in principal in relation to flood risk to the proposals based on the details provided thus far. Protection of Groundwater Approved Document Part H of the Building Regulations 2000 establishes a hierarchy for surface water disposal, which encourages a SUDS approach. Under Approved Document Part H the first option for surface water disposal should be the use of SUDS, which encourage infiltration such as soakaways or infiltration trenches. In all cases, it must be established that these options are feasible, can be adopted and properly maintained and would not lead to any other environmental problems. For example, using soakaways or other infiltration methods on contaminated land carries groundwater pollution risks and may not work in areas with a high water table. Where the intention is to dispose to soakaway, these should be shown to work through an appropriate assessment carried out under Building Research Establishment (BRE) Digest 365. Cont/d.. 2 If it is proposed to incorporate a SUDS scheme into the drainage proposals, it will need to be ensured that it is designed in accordance with the following guidance: The documents indicate that it is no longer intended to develop a groundwater supply at the site. We are aware of the pumping test that was undertaken by Ford Consulting in 2010 under a Section 32 Consent. If it is intended to revisit the option of developing a groundwater supply at the site, the developer should contact the Groundwater Team at the Environment Agency to discuss the proposals. CIRIA C522 document Sustainable Drainage Systems-design manual for England and Wales CIRIA C697 document SUDS manual the Interim Code of Practice for Sustainable Drainage Systems. The Interim Code of Practice provides advice on design, adoption and maintenance issues and a full overview of other technical guidance on SUDS. The Interim Code of Practice is available on both the Environment Agency's website: www.environment-agency.gov.uk and CIRIA's website: www.ciria.org.uk Managing Waste Waste from the development must be re-used, re-cycled or otherwise disposed of in accordance with waste management legislation and in particular the Duty of Care. Further information can be obtained from your local Environment Agency office. Any waste excavation material or building waste generated in the course of the development must be disposed of satisfactorily and in accordance with section 34 of the Environmental Protection Act 1990. Carriers transporting waste from the site must be registered waste carriers. The proposed development may involve carrying out an exempt activity as set out in Schedule 3 to the Waste Management Licensing Regulations 1994. This would require registration. Contact Jon Turner on 07990 776702 for further details. Variation to Existing IPPC Permit The Centrica proposals for the biomass plant will be dealt with by ourselves as a variation to an existing permit. The proposals, as outlined, constitute a substantial change to operation because the new plant is over 50 megawatts (thermal input) and the IPPC Directive - plus domestic legislation - define it as such. We consider it unlikely that the proposed new plant would represent a substantial change by the general definition of "...significant negative effects on human health or the environment." the definition in the IPPC Directive and the one carried forward into the Industrial Emissions Directive which subsumes IPPC. However, until we have receive an application for a permit variation with the associated detailed information we cannot say anything more definitive about the impact of the new plant. Biodiversity We are concerned about the following risks and potential impacts: -partial loss/damage of a designated site due to the new rail link. -changes in aerial emmision impacting on designated area and species. -disturbance to protected species and their habitats (in particular otter) All of these issues should be covered in the Habitat Regulations and CROW assessments which Natural England will advise you on. Cont/d.. 3 The survey information on otter usage of the area is incomplete due to lack of access. If the suspected otter holt is in an area which will be disturbed as part of the works further survey will be required so a suitable method statement can be agreed. If the area around the suspected holt is not to be disturbed we are satisfied with the information provided. Haditats Regulations Assessment We consider it good practice for you to complete one Habitats Regulations Assessment for both your application to the IPC and for your Environmental Permit Variation and we are pleased that you have indicative that you intend to do this. It is therefore important that the assessment that you complete at the moment is suitable to be used to alongside your permit variation application. We recommend that you refer to the attached Environment Agency documents which indicate how we will manage a Habitats Regulations Assessment of any permit variation: Operational Instruction
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