K3 Generating Station) and Wheelabrator Kemsley North (WKN

© 2019 RPS Group Notes 1. This drawing has been prepared in accordance with the scope of RPS’s appointment with its client and is subject to the terms and conditions of that appointment. RPS accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared and provided. 2. If received electronically it is the recipients responsibility to print to correct scale. Only written dimensions should be used.

Environmental Statement Volume 1: Main Chapters 20 Western Avenue, Milton Park, Abingdon, Oxfordshire,F: +44(0)1235 OX14 4SH 834 698 E: [email protected] T: +44(0)1235 821 888

Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North Wheelabrator Technologies Inc (WKN) Waste to Energy facility Development Consent Order Client

PINS Ref: EN010083 Project K3 and WKN DCO

Planning Act 2008 Title K3 and WKN Illustrative CGI The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 Regulation: 5(2)(a) Drawn By: PM/Checked By Status CR TS Document 3.1 FINAL Date Created September 2019 - Submission Version Scale @ A3 Job Ref MAR 2019 OXF9812 NTS Document Number Document Reference 5.10 9812-0052-02

O:\9812 Kemsley Construction Phase\Tech\Drawings\9812-0052-02.mxd O:\9812 Kemsley Construction Phase\Tech\Drawings\9812-0052-02.mxd Construction Kemsley O:\9812

Infrastructure Planning (Environmental Impact Assessment) (England and Wales) Regulations 2017

ENVIRONMENTAL STATEMENT – MAIN REPORT

Client: Wheelabrator Technologies Inc. Project: Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order Date: September 2019 Reference: Document 3.1 Editors: Tim Spicer BSc MSc PIEMA

DHA Environment Eclipse House Eclipse Park Sittingbourne Road Maidstone Kent ME14 3EN

Tel: 01622 776226 Email: [email protected] Web: www.dhaenvironment.co.uk

Part of the DHA Group Planning | Urban Design | Transport | Environment

Wheelabrator Technologies Inc Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order

Contents

1 INTRODUCTION

1.1 Background ...... 1 1.2 Environmental Impact Assessment ...... 2 1.3 ES Content ...... 4 1.4 Other Documentation ...... 4 1.5 Wheelabrator Technologies Inc...... 4 1.6 The Consultant Team ...... 5 1.7 ES Availability ...... 5 1.8 Making representations on the application ...... 6

2 SITE DESCRIPTION AND PROPOSED DEVELOPMENT

2.1 Introduction ...... 1 2.2 The Site(s) and wider area ...... 1 2.3 Proximity to Sensitive Sites ...... 1 2.4 Planning History ...... 2 2.5 Overview of K3 as consented ...... 3 2.6 K3 and WKN Proposed Developments ...... 7 2.7 K3 Proposed development ...... 8 2.8 WKN Proposed Development ...... 10 2.9 Parameters ...... 10 2.10 Construction of the WKN Proposed Development...... 16 2.11 WKN Post construction ...... 20 2.12 Management of risk and disasters for the K3 and WKN Proposed Developments ...... 23 2.13 Decommissioning the K3 and WKN Proposed Developments ...... 25 2.14 Alternatives and Primary Mitigation ...... 26

3 METHODOLOGY

3.1 Introduction ...... 1 3.2 The scope of the EIA ...... 1 3.3 Key issues identified in scoping ...... 5 3.4 Section 42 Consultation and Section 48 Publicity ...... 5 3.5 EIA assessment methodology – general approach ...... 9 3.6 Determining the significance of effects in the ES ...... 11 3.7 Identification of mitigation measures and significant residual effects ...... 14 3.8 Cumulative effects ...... 14 3.9 General format of the topic chapters ...... 19 3.10 Assumptions and Limitations ...... 20

4 TRAFFIC AND TRANSPORT

4.1 Introduction ...... 1 4.2 Regulatory and Policy Framework ...... 1 4.3 Methodology ...... 10 4.4 Baseline Conditions ...... 17 4.5 Future baseline ...... 24 4.6 K3 Proposed Development ...... 32 4.7 The Practical Effect of the K3 Proposed Development Predicted Effects ...... 41 4.8 WKN Predicted Effects ...... 46 4.9 Cumulative Effects ...... 62

Environmental Statement Volume 1– September 2019 Ref: EN010083 – Document 3.1 Wheelabrator Technologies Inc Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order

4.10 Cumulative Effects of K3 Proposed Development ...... 65 4.11 Cumulative Effects of the Practical Effect of the K3 Proposed Development ...... 77 4.12 Cumulative Effects of WKN Proposed Development During Construction ...... 82 4.13 Cumulative Effects of K3 and WKN Proposed Developments ...... 94 4.14 Completed Development Effects – 2024 ...... 95 4.15 Cumulative Effects of the practical effects of the K3 Proposed Development and WKN 4.16 Completed Development Effects – 2024 ...... 95 4.17 Summary ...... 95 References ...... 95

5 AIR QUALITY

5.1 Introduction ...... 1 5.2 Regulatory and Policy Framework ...... 1 5.3 Methodology ...... 10 5.4 Existing Baseline Conditions ...... 21 5.5 Assessment baseline ...... 26 5.6 The K3 Proposed Development ...... 26 5.7 The Practical Effect of the K3 Proposed Development ...... 37 5.8 Mitigation for the K3 Proposed Development ...... 41 5.9 Residual Effects ...... 42 5.10 WKN Proposed Development Predicted Effects ...... 42 5.11 Mitigation...... 53 5.12 Residual Effects ...... 55 5.13 Cumulative Effects ...... 55 5.14 Summary ...... 74 References ...... 76

6 CLIMATE CHANGE

6.1 Introduction ...... 1 6.2 Regulatory and Policy Framework ...... 1 6.3 Methodology ...... 9 6.4 Baseline Conditions ...... 15 6.5 Future baseline ...... 15 6.6 The K3 Proposed Development Predicted Effects ...... 16 6.7 The Predicted Practical Effect of the K3 Proposed Development ...... 18 6.8 Mitigation...... 20 6.9 Residual Effects ...... 22 6.10 The WKN Proposed Development Predicted Effects ...... 22 6.11 Mitigation...... 24 6.12 Residual Effects ...... 25 6.13 Cumulative Effects ...... 26 6.14 Summary ...... 26 References ...... 29

7 NOISE & VIBRATION

7.2 Regulatory and Policy Framework ...... 1 7.3 Methodology ...... 8 7.4 Baseline Conditions ...... 15 7.5 Future baseline ...... 17 7.6 K3 Proposed Development Predicted Effects ...... 17 7.7 Mitigation...... 23 7.8 Residual Effects ...... 23

7.9 The practical effect of the K3 Proposed Development ...... 24 7.10 Mitigation...... 26 7.11 Residual Effects ...... 26 7.12 WKN Proposed Development Predicted Effects ...... 26 7.13 Mitigation...... 34 7.14 Residual Effects ...... 35 7.15 Cumulative Effects ...... 35 7.16 Summary ...... 55 References ...... 56

8 HUMAN HEALTH

8 HUMAN HEALTH ...... 1 8.1 Introduction ...... 1 8.2 Regulatory and Policy Framework ...... 1 8.3 Methodology ...... 4 8.4 Baseline Conditions ...... 8 8.5 Future Baseline ...... 10 8.6 The effect of K3 Proposed Development ...... 11 8.7 Mitigation...... 16 8.8 Residual Effects ...... 17 8.9 Mitigation...... 20 8.10 Residual Effects ...... 20 8.11 Mitigation...... 25 8.12 Residual Effects ...... 25 8.13 Cumulative Effects ...... 26 8.14 Summary ...... 36 References ...... 37

9 GROUND CONDITIONS

9.1 Introduction ...... 1 9.2 Regulatory and Legislative Framework ...... 1 9.3 Methodology ...... 5 9.4 Baseline Conditions ...... 10 9.5 Future Baseline ...... 20 9.6 K3 Proposed Development Predicted Effects ...... 20 9.7 WKN Proposed Development Predicted Effects ...... 20 9.8 Decommissioning and Demolition Effects ...... 31 9.9 Mitigation...... 31 9.10 Residual Effects ...... 34 9.11 Cumulative Effects ...... 34 9.12 Summary ...... 35 References ...... 37

10 WATER ENVIRONMENT

10.1 Introduction ...... 3 10.2 Regulatory and Policy Framework ...... 3 10.3 Methodology ...... 8 10.4 Baseline Conditions ...... 18 10.5 Standard Mitigation Measures ...... 25 10.6 Predicted Effects ...... 27 10.7 Mitigation...... 35 10.8 Residual Effects ...... 37

10.9 Cumulative Effects ...... 37 References ...... 39

11 ECOLOGY

11.1 Introduction ...... 1 11.2 Regulatory and Policy Framework ...... 1 11.3 Methodology ...... 8 11.4 Baseline Conditions ...... 15 11.5 Future baseline ...... 23 11.6 K3 Proposed Development Predicted Effects - Construction ...... 23 11.7 K3 Proposed Development Decommissioning ...... 27 11.8 Summary ...... 30 11.9 WKN Proposed Development Predicted Effects ...... 31 11.10 Residual Effects of the K3 and WKN Proposed Developments ...... 54 11.11 Cumulative Effects ...... 59 References ...... 77

12 LANDSCAPE AND VISUAL IMPACT

12.1 Introduction ...... 3 12.2 Regulatory and Policy Framework ...... 4 12.3 Methodology ...... 6 12.4 Baseline Conditions ...... 14 12.5 Future baseline ...... 31 12.6 WKN Predicted Effects ...... 31 12.7 Mitigation...... 48 12.8 Residual Effects ...... 50 12.9 Cumulative Effects ...... 50 12.10 Summary ...... 59 References ...... 62

13 ARCHAEOLOGY & CULTURAL HERITAGE

13.1 Introduction ...... 1 13.2 Regulatory and Policy Framework ...... 1 13.3 Methodology ...... 4 13.4 Baseline Conditions ...... 16 13.5 Future baseline ...... 21 13.6 K3 Proposed Development ...... 21 13.7 The practical effect of the K3 Proposed Development ...... 22 13.8 WKN Predicted Effects ...... 23 13.9 Mitigation...... 33 13.10 Residual Effects ...... 34 13.11 Cumulative Effects ...... 34 13.12 Summary ...... 36 References ...... 38

14 SUMMARY TABLES

15 GLOSSARY

FIGURES

Chapter 1 1.1 Site location plan Chapter 2 2.1 Aerial view of the K3 and WKN Sites July 2019 2.2a-d Designated sites in proximity to the K3 and WKN Sites 2.3 K3 as consented layout 2.4a-d K3 as consented elevations 2.5 CGI of how K3 is likely to look post completion 2.6 K3 Proposed Development process diagram 2.7a&b K3 Works Plan – WKN Works Plan 2.8 K3 Practical effect process diagram 2.9 WKN Parameter Plan 2.10 CGI of how K3 and the WKN Proposed Development will look together using worst case parameters. 2.11 WKN Proposed Development process diagram Chapter 3 3.1 EIA Significance matrix 3.2a&b Cumulative developments with 3&10km of the K3 and WKN Sites Chapter 4 4.1 Road links assessed 4.2 Summary of personal injury accidents 4.3 Strategic Road Network summary of personal injury accidents Chapter 5 5.1 Windrose diagram 5.2 Location of K3 and WKN Proposed Development stacks and sensitive receptors 5.3 Contour of Annual-me an NO2 PCs resultant from the practical effect of the K3 Proposed Development and WKN Proposed Development 5.4 Contour of 99.79th Percentile Hourly-mean NO2 PCs resultant from the practical effect of the K3 Proposed Development and WKN Proposed Development Chapter 6 - Chapter 7 7.1 Noise assessment locations 7.2 Baseline noise survey locations 7.3 K3 Proposed Development – operational noise 7.4 Practical Effect of K3 Proposed Development operational noise - Additional HGVs 7.5 WKN Proposed Development – construction noise (piling) 7.6 WKN Proposed Development – operational noise Chapter 8 8.1 Social and ecological determinants of health Chapter 9 9.1 Historic ground investigation locations

Chapter 10 - Chapter 11 11.1 Designated sites location plan 11.2 Protected species distribution 11.3 Phase I habitat survey map 11.4 WKN Proposed Development noise modelling- impact piling 11.5 WKN Proposed Development laydown down area HGV noise modelling 11.6 Habitat loss/gain plan Chapter 12 12.1 Zone of Theoretical Visibility (ZTV )10 km radius study area 12.2 K3 and WKN Sites – aerial photography 12.3 Landscape and relevant designations and National Landscape Character 12.4 Zone of Theoretical Visibility (ZTV) detail and photographic viewpoint locations 12.5-12.16 Viewpoint photographs 12.17 Landscape character – Swale District 12.18 Landscape character – Kent County Chapter 13 13.1 Site location plan 13.2 Historic Environment Records data plot 13.3 HEA data plot Chapter 14 - Chapter 15 -

TECHNICAL APPENDICES

Appendix 1.1 ES Author CVs Appendix 2.1 Draft CEMP for WKN Appendix 3.1 Scoping Report Appendix 3.2 PINS Scoping Opinion Appendix 3.3 Response to the PINS Scoping Opinion Appendix 3.4 S42 Consultation Responses Appendix 3.5 Response to S42 Consultation Appendix 4.1 Transport Assessment Appendix 4.2 Construction Traffic Management Plan for WKN Appendix 4.3 Travel Plan for WKN Appendix 5.1 Air Quality – Construction Assessment Methodology WKN Appendix 5.2 Air Quality – Stack Height Determination WKN Appendix 5.3 Air Quality - Baseline Appendix 5.4 Air Quality – Assessment Impacts on Ecological Receptors Appendix 5.5 Air Quality – Traffic Impacts Appendix 5.6 Odour Assessment Methodology Appendix 6.1 K3 Proposed Development Carbon Assessment Appendix 6.2 WKN Proposed Development Carbon Assessment Appendix 6.3 Practical Effect of the K3 Proposed Development Carbon Assessment

Appendix 7.1 Noise Survey Results Appendix 7.2 WKN Proposed Development Construction Noise Model Input Data Appendix 7.3 WKN Proposed Development Construction Noise and Vibration Assessment Appendix 7.4 WKN Proposed Development Operational Noise Model Input Data Appendix 7.5 WKN Proposed Development Operational Noise Assessment Appendix 8.1 Human Health Baseline Appendix 9.1 WKN Desk Study Ground Conditions Preliminary Risk Assessment Appendix 10.1 WKN Flood Risk Assessment Appendix 10.2 WKN Drainage Design Philosophy Appendix 11.1 Kemsley Ornithological Surveys Appendix 11.2 Habitats Regulation Assessment Report Appendix 11.3 Previous Ecological Baseline Surveys 2007-2009 Appendix 11.4 K3 as consented Ecological Mitigation and Management Plan Appendix 11.5 K3 as consented Ecological Mitigation Report Appendix 11.6 Natural England Discretionary Advice Appendix 11.7 K3 and WKN Outfall licences Appendix 11.8 WKN External Lighting Plan Appendix 12.1 LVIA Scoping Correspondence with KCC Appendix 13.1 WKN Desk Based Heritage Assessment

Environmental Statement Volume 1– September 2019 Ref: EN010083 – Document 3.1 Wheelabrator Technologies Inc. Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order

1 Introduction

1.1 Background

1.1.1 Wheelabrator Technologies Inc. (“the Applicant”) has made an application to the Secretary of State for Business, Energy and Industrial Strategy (SoS) for a Development Consent Order (‘DCO’) for the construction and operation of the Wheelabrator Kemsley (‘K3’ Generating Station) and the construction and operation of a waste-to-energy facility on adjacent land called Wheelabrator Kemsley North (‘WKN’). Figure 1.1 shows the location of the two developments and the DCO boundary.

1.1.1 Planning permission was granted under the Town and Country Planning Act 1990 by Kent County Council in 2012 for a sustainable waste-to-energy facility (K3). Construction of the plant began in July 2016 and is expected to be completed with the plant operational by late 2019. K3 as consented will be capable of processing 550,000 tonnes of waste per annum and will have a generating capacity of 49.9 megawatts (MW).

1.1.2 The Planning Act 2008 states that the construction or extension of an onshore generating station with a capacity of more than 50MW in England or Wales is considered by Section 14(1)(a) and Section 15 of the Act to be a ‘nationally significant infrastructure project’ (NSIP) and as such requires an application for a DCO to be made to the Planning Inspectorate (PINS) for determination and approval by the SoS.

1.1.3 The applicant has identified that K3 would be capable of processing an additional 107,000 tonnes of waste per annum and, without any change to the external layout or design, of generating an additional 25.1MW of electricity.

1.1.4 However in order for the K3 project to be properly categorised and consented as the construction of a generating station under the Planning Act 2008 the applicant is seeking consent for the construction of K3 at its total generating capacity of up to 75MW (49.9MW consented + 25.1MW upgrade) together with its proposed tonnage throughput of up to 657,000 tonnes per annum (550,000 consented + 107,000 tonnage increase) (the ‘K3 Proposed Development’).

1.1.5 Development Consent is also being sought for a proposed new waste-to-energy facility, capable of processing 390,000 tonnes of waste per annum, with a generating capacity of 42MW (“the WKN Proposed Development”). The WKN Proposed Development is not therefore a NSIP as its generating capacity is below 50MW. Instead WTI made a formal application on the 1st June 2018 to the SoS under Section 35 of the Planning Act 2008 for a direction as to whether the WKN Proposed Development together with any matters associated with it can be treated as a development for which Development Consent is required. The SoS issued his direction on the 27th June 2018 confirming that WKN is to be treated as development for which Development Consent is required, for reasons including that it is nationally significant when considered with other projects in the same field, there are clear benefits to the K3 and WKN Proposed Developments being assessed comprehensively through the same DCO process and the removal of the need for separate consents to be sought.

Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 1-1 Wheelabrator Technologies Inc. Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order

1.1.6 Consent for the K3 and WKN Proposed Developments will therefore be sought under a single application to the SoS via PINS for a single DCO.

1.1.7 Further information regarding the Applicant, the location of the site(s), the K3 and WKN Proposed Developments and relevant planning history including relevant plans are provided in Chapter 2.

1.2 Environmental Impact Assessment

1.2.1 Both the K3 and WKN Proposed Developments are of a type listed in part 10 Schedule 1 of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (hereafter the EIA Regulations) as waste disposal installations with a capacity exceeding 100 tonnes per day:

10. Waste disposal installations for the incineration or chemical treatment (as defined in Annex 1 to Directive 2008/98/EC under heading D9) of non-hazardous waste with a capacity exceeding 100 tonnes per day.

1.2.2 All development of a type listed in Schedule 1 of the EIA Regulations constitute EIA Development as defined in the EIA Regulations and the application for the K3 and WKN DCO is therefore required to be accompanied by an Environmental Statement (ES), prepared in accordance with the EIA Regulations. An Environmental Impact Assessment (EIA) has been carried out in accordance with the EIA Regulations to identify and assess the potential significant environmental effects of the K3 and WKN Proposed Developments. The results of this assessment are reported in this ES submitted with the application to PINS.

1.2.3 EIA is a process for ensuring that the likely significant effects of a new development on the environment are fully understood and taken into account before development is allowed to proceed. As defined in the DCLG EIA Planning Practice Guidance1:

“The aim of Environmental Impact Assessment is to protect the environment by ensuring that a local planning authority when deciding whether to grant planning permission for a project, which is likely to have significant effects on the environment, does so in the full knowledge of the likely significant effects, and takes this into account in the decision-making process.”

http://planningguidance.planningportal.gov.uk Paragraph: 002 Reference ID: 4-002- 20140306

1.2.4 The purpose of an ES is to report the findings of the EIA. In accordance with good practice guidance, this ES has been produced as a separate objective assessment of the potential environmental effects of the K3 and WKN Proposed Developments, albeit is integral to the planning process.

1 Whilst it is noted that the DCLG EIA Planning Practice Guidance relates principally to the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 the principle and purpose of EIA remains the same under the DCO process.

Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 1-2 Wheelabrator Technologies Inc. Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order

1.2.5 To satisfy the requirements of the EIA Regulations, an ES must address the matters as listed in Schedule 4 and Regulation 14 of the EIA Regulations as relevant.

1.1.1 The EIA process for the K3 and WKN Proposed Development will take account of the guidance provided by PINS in the form of the non-statutory National Infrastructure Advice Notes. These provide advice and information on a range of issues arising throughout the whole life of the application process as set out below:

• Advice Note Three: EIA consultation and notification (the Planning Inspectorate, 2017);

• Advice Note Seven: Environmental Impact Assessment, Preliminary Environmental Information, Screening and Scoping (the Planning Inspectorate, 2017);

• Advice Note Nine: Rochdale Envelope (the Planning Inspectorate, 2018);

• Advice Note Ten: Habitat Regulations Assessment (the Planning Inspectorate, 2017);

• Advice Note Twelve: Transboundary Impacts (the Planning Inspectorate, 2018);

• Advice Note Seventeen: Cumulative effects assessments (the Planning Inspectorate, 2019); and

• Advice Note Eighteen: The Water Framework Directive (the Planning Inspectorate 2017)

1.2.6 This ES been prepared by DHA Environment and RPS using information gathered during a formal EIA of the K3 and WKN Proposed Developments in winter 2018 to summer 2019. The EIA has considered the likely significant effects of the K3 and WKN Proposed Developments individually as well as cumulatively with each other and with other relevant consented and planned projects.

1.2.7 The scope of the EIA has been determined by DHA in consultation with PINS and Consultees following the precautionary principle. The scoping process is discussed further in Chapter 3.

1.2.8 In order to keep the size of this ES to a minimum, and because of the nature of the report, it inevitably contains some technical terminology and abbreviations. A glossary of technical terms and abbreviations is included at Chapter 15.

1.2.9 A Non-Technical Summary ("NTS") (Document 3.2) has also been provided in accordance with Paragraph 9 of Schedule 4 to the EIA Regulations. This is a standalone document which provides a simplified summary of the content and scope of the ES, the technical issues considered within it and the assessment of the environmental impacts undertaken.

Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 1-3 Wheelabrator Technologies Inc. Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order

1.3 ES Content

1.3.1 The ES is presented in 3 volumes.

1.3.2 Volume 1 comprises introductory chapters which set out the need for EIA; introduce the project team; set out the methodology used; describe the Site and the context for the K3 and WKN Proposed Developments; describe the K3 and WKN Proposed Developments; and set out the alternatives which were considered. It also includes the Technical Chapters, which are topic-specific assessments of the effects of the K3 and WKN Proposed Developments.

1.3.3 Volume 2 includes appendices to the main text of the ES, predominantly detailed topic-specific reports which support the assessments made in the ES.

1.3.4 Volume 3 is the NTS. In accordance with best practice guidance, the NTS has been prepared as a standalone report which is available free of charge. The NTS provides an illustrated summary of the key aspects of this ES report, designed to inform people of the environmental effects of the proposal and written in non- technical language.

1.4 Other Documentation

DCO Application Documents

1.4.1 A number of other documents have been submitted to PINS as part of the DCO application. These are listed in the Application Guide (Document 1.2) submitted with the DCO application.

1.5 Wheelabrator Technologies Inc.

1.5.1 Wheelabrator Technologies Inc. (“the Applicant”) is the second largest US waste- to-energy business and is an industry leader in the conversion of everyday residential and business waste into clean energy. Wheelabrator currently has a platform of 25 strategically located assets across the US and UK —19 waste-to- energy facilities (three under construction), two waste fuel facilities as well as four ash monofills. We also recover metals for recycling at two advanced metals recovery systems and one central upgrade facility. Wheelabrator currently has an annual waste processing capacity of over 7.2 million tonnes (8 million tons), and a total combined electric generating capacity of 732 megawatts—enough energy to power more than 671,100 US homes. Wheelabrator also recovers metals for recycling into commercial products. The company’s vision to develop, deliver and realize the potential of clean energy speaks to Wheelabrator’s ongoing commitment to the development of clean energy solutions for its customers and local communities. Wheelabrator is owned by Macquarie Infrastructure and Real Assets, a business within the Macquarie Asset Management division of Macquarie Group and a global alternative asset manager focused on real estate, infrastructure, and agriculture and energy assets.

1.5.2 For more information on Wheelabrator, please visit www.wtienergy.co.uk

Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 1-4 Wheelabrator Technologies Inc. Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order

1.6 The Consultant Team

1.6.1 The Applicant has appointed a number of specialist consultants (competent experts), the results of whose work are presented in this ES. Table 1.1 lists the consultants involved in identifying the development constraints and undertaking various aspects of the EIA.

Name & Organisation Discipline / Area of Expertise Tim Spicer, DHA Planning EIA Scoping, co-ordination and compilation and NTS David Archibald, RPS Traffic and Transport Fiona Prismall, RPS Air Quality Tom Dearing, RPS Climate Change Phil Evans, RPS Noise and Vibration Tara Barratt, RPS Human Health Graham Moore, RPS Ground Conditions Jonathan Morley, RPS Water Environment Nick Betson RPS Biodiversity Paul Ellis, RPS Land and Visual Impact Nick Cooke, RPS Cultural Heritage

1.6.2 In accordance with Regulation 14(4)(b) of the EIA Regulations a summary of the expertise and qualifications of the competent experts involved in the production of this ES are provided in Appendix 1.1.

1.7 ES Availability

1.7.1 Electronic copies of the ES, NTS and other application documents can be viewed and downloaded free of charge from the Applicant’s website:

www.wtikemsley.co.uk

1.7.2 Copies of the ES and NTS can also be inspected at the following locations until the conclusion of the examination period (anticipated June 2020), with typical opening hours shown:

Sittingbourne Library, Central 9:00am to 6:00pm Monday to Friday, Avenue, Sittingbourne, ME10 4AH 9:00am to 5:00pm Saturdays

Swale Borough Council Offices, East 8:45am to 5:00pm Monday to Street, Sittingbourne, ME10 3HT Thursday, 8:45am to 4:30pm Friday

Kent County Council Offices, County 9:00am to 4:00pm Monday to Friday Hall Reception, County Hall, Maidstone, Kent, ME14 1XQ9:

1.7.3 Additional copies of the ES (paper, USB or CD) may be obtained at a reasonable charge to reflect printing and distribution costs by contacting:

Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 1-5 Wheelabrator Technologies Inc. Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order

Email: [email protected]

Writing to: FREEPOST WHEELABRATOR KEMSLEY

Calling (freephone): 0800 062 2982

1.7.4 The following charges apply, to cover printing and administration costs.

(1) Full printed ES, including appendices - £500

(2) Printed ES, not including appendices - £50

(3) Printed Non-Technical Summary, singularly or in addition to the above – free

(4) Electronic CD copy of full ES, appendices and NTS - £25

1.8 Making representations on the application

1.8.1 Following submission, the Planning Inspectorate has up to a month to assess whether the DCO application is valid. The Applicant is required to publicise the acceptance of a DCO application, at which point details will be provided as to how to register with PINS to be an Interested Party during the DCO examination. At that stage there is the opportunity to make an initial representation regarding the content of the DCO application. All such Relevant Representations made will be published by PINS on their website.

1.8.2 Anyone registered as an Interested Party will then be updated by PINS as the examination of the application progresses. They will have the opportunity to attend and speak at the Preliminary Meeting, which considers how the examination will proceed, and then at any Hearings which take place during the examination period itself. In addition, Interested Parties can submit a detailed Written Representation and make submissions in response to the formal questions raised by the Inspector(s) and the submissions of the Applicant and other Interested Parties. Further information is available on PINS website:

https://infrastructure.planninginspectorate.gov.uk/application-process/the- process/

Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 1-6 ± Legend DCOBound a ry K3Site(Wo Area rks 1) W KNSite(Wo Area rks 2)

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Wheelabrator Technologies Inc Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order

3 Methodology

3.1 Introduction

This Chapter explains the process taken to identify the environmental issues considered by this ES and outlines the overall approach taken to the EIA. Specific methodologies for each of the specialist studies are given in the relevant topic chapters.

3.2 The scope of the EIA

Scoping is the identification of the range of potentially significant issues likely to arise as a result of a proposed development. The advice given in the DCLG EIA guidance1 (under the heading “What Information should the Environmental Statement contain”) is that:

“Whilst every Environmental Statement should provide a full factual description of the development, the emphasis of Schedule 4 is on the “main” or “significant” environmental effects to which a development is likely to give rise. The Environmental Statement should be proportionate and not be any longer than is necessary to assess properly those effects. Where, for example, only one environmental factor is likely to be significantly affected, the assessment should focus on that issue only. Impacts which have little or no significance for the particular development in question will need only very brief treatment to indicate that their possible relevance has been considered.”

http://planningguidance.planningportal.gov.uk/ Paragraph: 033 Reference ID: 4-035- 20170728

This approach is reinforced by case law. Judgments have stated that, even in relation to the minimum requirements for an ES, not every possible effect has to be considered. The focus should be on the main effects and on remedying the significant adverse effects. The Milne judgment states that, “the Environmental Statement does not have to describe every environmental effect, however minor, but only the main effects or likely significant effects”.2 The Tew judgment noted that the underlying objective of EIA is that decisions be taken “in full knowledge” of a project’s likely significant effects and stated: 3

“…that is not to suggest that full knowledge requires an environmental statement to contain every conceivable scrap of environmental information about a particular project. The directive and the Assessment Regulations

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require likely significant effects to be assessed. It will be for the local planning authority to decide whether a particular effect is significant”.

The purpose of scoping is therefore to ‘scope in’ only those aspects considered to have likely significant environmental effects. Where a particular environmental feature, or component of it, has not been included within the proposed scope of the EIA, this is not to suggest that there will be no associated effects; rather that these are not considered to be among the potentially significant effects.

DHA working with RPS, undertook a scoping exercise and produced an EIA Scoping Report in July 2018. This document provided a summary of the changes sought to K3 and the WKN Proposed Development, identified the main environmental effects to be assessed within the EIA and scoped out issues that did not require consideration but were to be kept under review throughout the EIA process ensuring that any new potentially significant effects identified were included.

In accordance with the Infrastructure Planning (EIA) Regulations 2017 (the “EIA Regulations”) the following factors influenced the breadth of the scoping exercise and so the EIA:

• The specific characteristics of the K3 and WKN Proposed Developments;

• The environmental features likely to be affected by the K3 and WKN Proposed Developments;

• The extent of any likely impact;

• The trans frontier nature of the impact;

• The magnitude and complexity of the impact;

• The probability of the impact;

• The duration, frequency and reversibility of the impact.

A formal request for a Scoping Opinion was made to PINS in August 2018. PINS, in accordance with the EIA Regulations consulted a number of statutory and non- statutory bodies on the proposed scope of the EIA. Table 3.1 provides a list of the statutory and non-statutory bodies consulted by PINS.

The Health and Safety Executive* NHS England Swale Clinical Commissioning Group Natural England* Historic England Kent Fire and Rescue Service Kent Police and Crime Commissioner The Environment Agency* Maritime and Coastguard Agency* The Marine Management Organisation* Civil Aviation Authority

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Kent County Council Highways Authority Highways England* Trinity House* Public Health England* The Crown Estate Forestry Commission Ministry of Defence Network Rail Infrastructure Ltd Highways England Historical Railways South East Coast Ambulance Service NHS Foundation Trust NATS En-Route Safeguarding* Royal Mail Group* Homes England Southern Water Cadent Gas Limited Energetics Gas Limited Energy Assets Pipelines Limited ES Pipelines Ltd* ESP Connections Ltd* ESP Networks Ltd ESP Pipelines Ltd Fulcrum Pipelines Limited GTC Pipelines Limited Independent Pipelines Limited Indigo Pipelines Limited Quadrant Pipelines Limited National Grid Gas Plc* Scotland Gas Networks Plc Southern Gas Networks Plc Wales and West Utilities Ltd Energetics Electricity Limited Energy Assets Networks Limited Energy Assets Power Networks Limited ESP Electricity Limited Fulcrum Electricity Assets Limited G2 Energy IDNO Limited Harlaxton Energy Networks Limited Independent Power Networks Limited Leep Electricity Networks Limited Murphy Power Distribution Limited The Electricity Network Company Limited UK Power Distribution Limited Utility Assets Limited Vattenfall Networks Limited Utility Distribution Networks Limited UK Power Networks Limited

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National Grid Electricity Transmission Plc* Swale Borough Council* Medway Council* Ashford Borough Council Canterbury City Council* Maidstone Borough Council Thurrock Council Kent County Council* East Sussex County Council Surrey County Council London Borough of Bexley* London Borough of Bromley Royal National Lifeboat Institution *consultation bodies who replied.

Table 3.1: Organisations consulted by PINS on the scope of the EIA. A copy of the EIA Scoping Report issued to PINS can be found in Appendix 3.1 and a copy of PINS formal Scoping Opinion pursuant to this including statutory consultee responses is provided as Appendix 3.2.

In addition to the above individual topic authors have approached consultees directly to agree the methodology and scope of the assessments where necessary and this is reported in topic chapters as relevant.

It should be noted that at the time of scoping the intention was to apply for an extension to K3 as consented to comprise a power upgrade from 49.9MW to 75MW and an increase in annual permissible waste throughput of 107,000tpa.

In order for the K3 project to be properly categorised and consented under the Planning Act 2008 the applicant is seeking consent for the construction of K3 at its total generating capacity of 75MW (49.9MW consented + 25.1MW upgrade) together with its proposed tonnage throughput of 657,000 tonnes per annum (550,000 consented + 107,000 tonnage increase) (the ‘K3 Proposed Development’).

However, the practical effect of the K3 Proposed Development would simply allow K3 as consented to generate an additional 25.1MW and process an additional 107,000 tpa of waste i.e. the same effect of proposed development at the time of scoping.

Construction of K3 began in July 2016 and is expected to be completed with the facility operational by late 2019. The DCO being consent sought would not result in any additional external physical changes to K3 as consented and the layout and appearance of the facility would remain as per its consented design.

It is therefore considered that the Scoping Report and the subsequent Scoping Opinion issued by PINS remains relevant to the practical effect of the DCO. However, in order to ensure that the effect of the development as whole is

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assessed appropriately within the ES some amendments to the scope of the ES have been made. These are set out where relevant herein.

3.3 Key issues identified in scoping

Responses were received from nineteen of the organisations consulted (as identified in Table 3.1)

The Scope of the ES has been amended to take note of the issues raised during the scoping process. Appendix 3.3 provides a summary table identifying where each of the issues identified during scoping are addressed within the ES or provides justification as to why these issues can subsequently be scoped out of the ES.

Where a particular environmental feature, or component of it, has not been included within the ES, this is not to suggest that there will be no associated effects; rather that these are not considered to be among the potentially significant effects.

3.4 Section 42 Consultation and Section 48 Publicity

The approach taken by the Applicant to pre-application consultation and publicity is explained in full in the Consultation Report [Document 4.1] which forms part of the DCO application.

Section 42 of the Planning Act 2008 requires the applicant to consult various prescribed bodies, directly affected and adjoining local authorities, the Greater London Authority where relevant and any parties identified under S44, such as owner, lessees, tenants or occupiers and others.

Section 48 of the same Act requires the applicant to publicise the proposed application in the prescribed manner.

Three rounds of Section 42 consultation, S47 (local community) consultation and Section 48 publicity have now been undertaken.

2017

The first round of consultation and publicity took place in 2017, prior to the construction of K3 having been commenced. At that stage the proposal on which consultation and publicity was undertaken comprised the construction and operation of K3 to an upgraded generating capacity of 75MW. The proposals at that time did not include any tonnage throughput capacity increase, or the proposed WKN facility.

2018

The second round of consultation and publicity took place in 2018, by which point the construction of K3 was advanced. As K3 was being constructed the consultation and publicity sought views regarding a power upgrade of K3 from 49.9MW to 75MW. By that stage the applicant had reviewed the potential waste

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throughput of the K3 facility and views were also sought regarding an increase to the annual permissable waste throughput of 107,000 tonnes, resulting in a total proposed annual tonnage throughput of 657,000 tonnes. The consultation made clear that no construction works were necessary for that upgrade or tonnage throughput increase. The consultation and publicity also included the construction and operation of the WKN facility on the land adjacent to K3.

Section 42 consultation packs were sent to the required parties from the 30th November 2018. A draft ES was produced pursuant to the EIA Scoping process and formed the basis on which the S42 Consultation was undertaken. A copy of the consultation letter with a link to the relevant documents on the Applicants website is provided in Technical Appendix 3.4.

Statutory notices under Section 48 were placed in locally circulating newspapers on the 28th November, 3rd December, 5th December and 10th December 2018, the London Gazette on the 4th December 2018 and the Daily Telegraph on the 5th December 2018.

Responses were received from 22 of the organisations consulted under Section 42 (as identified in Table 3.2). No responses were received as a result of the Section 48 notices.

The Scope of the ES has been amended where relevant to take note of the issues raised during the S42 consultation process. Technical Appendix 3.5 provides a summary table identifying where each of the issues identified during the S42 consultation are addressed within the ES or provides justification as to why these issues can subsequently be scoped out of the ES.

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Trinity House* Public Health England The Crown Estate Forestry Commission Ministry of Defence Royal National Lifeboat Institution South East Coast Ambulance Service NHS Foundation Trust Highways England Historical Railways Estate Network Rail Infrastructure Limited* NATS En-route (NERL) Safeguarding* Royal Mail Group* Homes England Southern Water* Thames Water Utilities Limited Cadent Gas Limited Energetics Gas Limited Energy Assets Pipelines Limited ES Pipelines Ltd ESP Connections Ltd* ESP Networks Ltd* ESP Pipelines Ltd* Fulcrum Pipelines Ltd GTC Pipelines Ltd Independent Pipelines Ltd Indigo Pipelines Ltd Quadrant Pipelines Limited National Grid Gas Plc Scotland Gas Networks Plc Southern Gas Networks Plc Wales and West Utilities Ltd Energetics Electricity Limited Energy Assets Network Limited Energy Assets Power Networks ESP Electricity Limited* Fulcrum Electricity Assets Limited G2 Energy IDNO Limited Harlaxton Energy Networks Limited* Independent Power Networks Limited Leep Electricity Networks Limited Murphy Power Distribution Limited The Electricity Network Company Limited UK Power Distribution Limited Utility Assets Limited Utility Distribution Networks Limited UK Power Networks Limited Vattenfall Networks Limited

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National Grid Electricity Transmission PLC British Telecommunications Plc EE Limited Virgin Media Communications Limited O2 Limited Cornerstone Telecommunications Infrastructure Limited Swale Borough Council Medway Council* Ashford Borough Council Canterbury City Council* Maidstone Borough Council Thurrock Council Kent County Council* East Sussex County Council Surrey County Council* London Borough of Bexley London Borough of Bromley *consultation bodies who replied. Excludes Section 44 consultees – owner, lessee, tenant, occupier Table 3.1: Organisations consulted as part of S42 Consultation on the scope of the EIA November 2018

2019

In order to properly categorise and consent the development under the Planning Act 2008 consent is now being sought for the construction and operation of K3 up to a generating capacity of 75MW, as well as seeking consent for an annual throughput of 657,000 tonnes of waste.

A further round of S42 and S47 consultation and S48 publicity was therefore undertaken in July 2019 on the description of development as it is now set out within the application, i.e. the construction and operation of a 75MW generating station with a total annual throughput of 657,000tpa, together with the construction and operation of the WKN facility. The intention of the third round of consultation and publicity was to inform interested stakeholders about the change to the description of development and to clarify the effect of that on the approach to EIA within the application, in order to allow them the opportunity to comment on the application in those terms prior to submission.

A PEIR was produced pursuant to the EIA Scoping process and formed the basis on which the S42 Consultation was undertaken. A copy of the consultation letter with a link to the relevant documents on the Applicants website is provided in Technical Appendix 3.6.

Statutory notices under Section 48 were placed in locally circulating newspapers on the 24th, 29th and 31st July 2019 and 5th and 12th August 2019, the London Gazette online 30th July 2019 and in the paper 31st July 2019 and the Daily Telegraph on the 31st July 2019.

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Responses were received from 20 of the organisations consulted under Section 42 (as identified in Table 3.3). One Section 48 response was received but was unrelated to the ES.

The Scope of the ES has been amended where relevant to take note of the issues raised during the S42 consultation process. Technical Appendix 3.7 provides a summary table identifying where each of the issues identified during the S42 consultation are addressed within the ES or provides justification as to why these issues can subsequently be scoped out of the ES.

Health and Safety Executive* NHS England NHS Swale Clinical Commissioning Group Natural England* Historic England* Kent Fire and Rescue Service Kent Police and Crime Commissioner Bapchild Parish Council Bobbing Parish Council* Borden Parish Council Iwade Parish Council Minster-on-Sea Parish Council* Rodmersham Parish Council Tonge Parish Council Tunstall Parish Council Environment Agency* Maritime and Coastguard Agency Marine Management Organisation Civil Aviation Authority Kent County Council Highways* Highways England Lower Medway IDB Trinity House* Public Health England The Crown Estate Forestry Commission Ministry of Defence Royal National Lifeboat Institution South East Coast Ambulance Service NHS Foundation Trust Highways England Historical Railways Estate Network Rail Infrastructure Limited* NATS En-route (NERL) Safeguarding* Royal Mail Group* Homes England Southern Water Thames Water Utilities Limited Cadent Gas Limited Energetics Gas Limited

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Energy Assets Pipelines Limited ES Pipelines Ltd ESP Connections Ltd ESP Networks Ltd ESP Pipelines Ltd Fulcrum Pipelines Ltd GTC Pipelines Ltd Independent Pipelines Ltd Indigo Pipelines Ltd* Quadrant Pipelines Limited National Grid Gas Plc* Scotland Gas Networks Plc Southern Gas Networks Plc* Wales and West Utilities Ltd Energetics Electricity Limited Energy Assets Network Limited Energy Assets Power Networks ESP Electricity Limited* Fulcrum Electricity Assets Limited G2 Energy IDNO Limited Harlaxton Energy Networks Limited* Independent Power Networks Limited Leep Electricity Networks Limited Murphy Power Distribution Limited The Electricity Network Company Limited UK Power Distribution Limited Utility Assets Limited Utility Distribution Networks Limited UK Power Networks Limited Vattenfall Networks Limited National Grid Electricity Transmission PLC* British Telecommunications Plc EE Limited Virgin Media Communications Limited O2 Limited Cornerstone Telecommunications Infrastructure Limited Swale Borough Council* Medway Council* Ashford Borough Council Canterbury City Council* Maidstone Borough Council Thurrock Council Kent County Council East Sussex County Council Surrey County Council London Borough of Bexley*

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London Borough of Bromley *consultation bodies who replied. Excludes Section 44 consultees – owner, lessee, tenant, occupier Table 3.2: Organisations consulted as part of S42 Consultation on the scope of the EIA July 2019

3.5 EIA assessment methodology – general approach

An environmental effect is an alteration, positive or negative, to some aspect of the environment (sensitive receptors4) that occur as a result of a proposed development.

The project team has considered the likely positive and negative significant environmental effects of the K3 and WKN Proposed Developments. These effects are reported in this ES, taking into account current knowledge of the Site(s) and their surroundings (baseline), and drawing upon the findings of a variety of studies which have all contributed to the EIA process.

It is important that the assessment methodology distinguishes between the sensitivity of the receptor and the type and size of change that will affect the receptor, either directly or indirectly. Where significant effects have been identified, the relevant Technical Chapter also proposes mitigation measures (i.e. ways of avoiding, limiting or offsetting potentially significant effects) where possible.

This ES has been produced following published guidance, information on best practice and PINS advice notes 7, 9 and 17. The methodologies used for the specific topics are discussed in the relevant chapters of the ES.

K3 Proposed Development

The ES has assessed the likely positive and negative significant environmental effects of the K3 Proposed Development.

Construction of K3

The application for the K3 Proposed Development in accordance with the Planning Act 2008 seeks Development Consent for the construction and operation of the Wheelabrator Kemsley Generating Station (‘K3’) with a 75MW generating capacity and 657,000tpa waste throughput. However, the practical effect of the DCO application is to permit K3 as consented and constructed to operate at an upgraded capacity of up to 75MW (an additional 25.1 MWe) and to process an additional 107,000 tonnes of waste per annum beyond that possible under its existing Town and Country Planning permission

Construction of K3 began in July 2016 and is expected to be completed with the facility operational by late 2019. The DCO being consent sought would not result

4 A receptor is a part of the natural or man-made environment, such as a river, woodland, protected species, a person or a building, that is affected by an impact.

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in any additional external physical changes to K3 as consented and the layout and appearance of the facility would remain as per its consented design.

The effects of the construction of K3 were fully assessed as part of Environmental Impact Assessment undertaken, submitted and approved as part of existing planning consent (as amended) (this is provided as Document 3.3 submitted with the application). There will be no physical additional construction works to K3. The physical elements of the facility will remain as consented.

No further assessment of the effects of constructing K3 has therefore been undertaken except where potential effects pursuant to the EIA Regulations 2017 were not assessed as part of the existing planning permission i.e. human health and climate change.

The operation of the K3 Facility

The assessment of the operation of the K3 Proposed Development is assessed in two parts;

• The K3 Proposed Development assuming the absence of the operation of K3 as consented i.e. the effect of a 75MW Generating Station processing 657,000tpa per annum of waste.

• The practical effect of the K3 Proposed Development which is K3 as consented (forming the baseline) and the effect of an additional 25.1 MWe generating capacity and the processing an additional 107,000 tonnes of waste per annum.

The presentation of the practical effect of the K3 Proposed Development is deemed relevant as it will be the effect of the application in real terms if consented.

The ES also considers and potential effects of decommissioning of the K3 Proposed Development at a future date.

WKN Proposed Development

The ES has considered the likely positive and negative significant environmental effects during the construction of the WKN Proposed Development, once the development is operational, and the potential effects of decommissioning of the plant at a future date.

For the assessment of the WKN Proposed Development the baseline for the assessments is K3 as consented; as it is substantially constructed and capable of being operated under its existing permission there is not a scenario where the WKN Proposed Development would be present without K3.

The effect of the K3 and WKN Proposed Developments in combination is addressed as part of the cumulative effects assessments for each topic. In a wider

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context there are a number of cumulative developments within the zone of influence of the K3 and WKN Sites, a significant number of which have planning permission (see section 3.8).

Where a different approach has been taken to that set out above this is expressly stated and justified within the relevant topic chapters.

3.6 Determining the significance of effects in the ES

The purpose of the ES is to identify the positive and negative environmental effects of a scheme, including an assessment of the degree to which such effects are likely to be significant. The evaluation of the significance of an effect is fundamental to the EIA process. The degree of an effect i.e. significant or not- significant determines the resources that should be deployed in avoiding or mitigating an adverse effect. Conversely it identifies the degree of value of a beneficial effect.

The degree of an effect is determined by the interaction of two factors: (i) the magnitude, scale, severity or probability of an impact or change, and (ii) the value, importance or sensitivity of the resource being affected. This is then used to determine whether an effect is significant or not. Figure 3.1 shows the general matrix5 used to determine the degree of each effect identified and whether an effect is significant. Typically if the effect is moderate or above then the effect is considered to be significant i.e. it is likely to be a material factor in the decision whether to grant consent. Slight or negligible effects are not considered to be significant. Where any topic specific methodologies differ from this approach these are explained in the relevant topic chapters.

5 Adapted from figure 6.3 of the Institute of Environmental Assessment and Management’s State of Environmental Impact Assessment Practice in the UK 2011.

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Figure 3.1: Significance matrix

As a general rule significance is determined taking into account a variety of factors. These include:

• the value of the resource (e.g. whether it is of international, national, regional and local level importance);

• the magnitude of the impact;

• the duration involved;

• the reversibility of the effect; and

• the number and sensitivity of receptors.

As far as possible, standard words have been used to define degrees of effect (i.e. “very substantial”, “substantial”, “moderate”, “slight” and “negligible”), but not so rigorously as to remove the flexibility of professional judgement. It is noted that a number of topics e.g. air quality and ecology have their own individual requirements and professional body guidance with regard to impact classification

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and degree of significance. Therefore, in accordance with best practice guidance, significance has been determined on the basis of expert judgement and industry specific guidelines. To ensure that the manner in which significance has been attributed is transparent and repeatable, the aforementioned standard words are used where feasible to define the degrees of effect.

Although the environmental effects described in the ES are under discrete headings, the EIA has paid close attention to the interrelationships between the topic areas in order to assemble a holistic picture of the likely significant effects and mitigation measures.

Table 3.2 below shows the topic areas that are likely to impact upon other topic areas and result in intra-project effects that could be significant. To this regard topic authors have co-ordinated their assessments where relevant to address potential intra-project effects e.g. the effects of construction noise on ecological receptors. Cross references between assessments are made where appropriate.

Affected By

TrafficTransport and AirQuality Change Climate Vibration Noiseand Humanhealth ConditionsGround WaterEnvironment Biodiversity visual and Landscape impacts heritage Cultural Traffic and transport

Air Quality X

Climate Change X X

Noise and Vibration X Impacted on Impacted Human health X

Ground conditions

Water Environment X X

Biodiversity X X X X X

Landscape and visual X6 X impacts Cultural heritage X X

6 Achieving sufficient emission dispersal and consequently acceptable emission levels is a determining factor in stipulating stack height which turn affects visual impact.

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3.7 Identification of mitigation measures and significant residual effects

Where appropriate, the identification of significant effects has helped to guide the mitigation measures proposed. The effects of the K3 and WKN Proposed Developments with the proposed mitigation in place are then reassessed to determine the significance of effect post mitigation. At the end of each environmental assessment, where relevant, there is a residual effects table, which summarises any likely significant environmental effects remaining after mitigation. Any significant effects remaining after mitigation or which cannot be mitigated are reported appropriately within the Technical Chapter and a summary of all significant residual effects provided in Chapter 14.

3.8 Cumulative effects

The effects of the K3 and WKN Proposed Development in combination with other schemes that are operational / constructed, consented or for which planning permissions are currently being sought, has been assessed within the EIA where appropriate.

With regard to cumulative effects the ES has assessed the following scenarios as relevant:

• Baseline + K3 Proposed Development + other relevant cumulative developments within the zone of influence of the K3 Proposed Development

• K3 as consented + the practical effect of the K3 Proposed Development + WKN Proposed Development + other relevant cumulative developments within the zone of influence of the K3 Proposed Development

• Baseline + K3 Proposed Development + WKN Proposed Development + other relevant cumulative developments within the zone of influence of the K3 and WKN Proposed Developments

• K3 as consented + the practical effect of the K3 Proposed Development + WKN Proposed Development + other relevant cumulative developments within the zone of influence of the K3 and WKN Proposed Developments

• K3 as consented + WKN Proposed Development + other relevant cumulative developments within the zone of influence of the WKN Proposed Developments

Cumulative effects will be considered on an issue-by-issue basis and the scope of the EIA will be expanded, if necessary, to include any cumulative issues that arise in the future. The cumulative effects of other developments will be considered only where sufficient information is available, i.e. when a project is within the planning domain and there is adequate information publicly available.

All large-scale development within 3km of the Site(s) and all large energy, industrial and mixed-use schemes for the purposes of the air quality and landscape

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and visual impacts (i.e. of a similar type to the K3 and WKN Proposed Developments and therefore most likely to result in significant effects) within 10km of the site(s) have been identified for assessment in the ES. A total of 46 cumulative sites have been considered for their potential cumulative effects (see Figures 3.2a&b):

1. SW/11/1291 Anaerobic digester and associated ground profiling and landscaping.

2. SW/14/0224 Solar farm, comprising the erection of solar arrays of photovoltaic panels, inverter and transformer sheds, fencing, site storage cabin, combined DNO and EPC switchgear housing, internal gravel access road, and associated equipment.

3. 14/500327/OUT Up to 8000m2 of Class B1 and B2 floor space and all necessary supporting infrastructure including roads, parking, open space, amenity landscaping, biodiversity enhancement and buffer to proposed extension to Milton Creek Country Park. Detailed approval for Phase 1 including (i) vehicular and pedestrian access to Swale Way; (ii) 30 space (approximately) informal car park to serve extension to Milton Creek Country Park; Change of use of approximately 13.31 ha of Kemsley Marshes as an extension to Milton Creek Country Park with footpath connections to the proposed informal car park

4. 14/501181/COUNTY KCC Regulation 13 - Scoping opinion as to the scope of an environmental impact assessment for a proposed combined heat and power plant at Ridham B

5. 15/500348/COUNTY Install advance thermal conversion and energy facility at Kemsley Fields Business Park to produce energy and heat, including construction of new buildings to house thermal conversion and energy generation plant and equipment; construction of associated offices; erection of external plant including storage tanks; and erection of discharge stack (KCC planning application KCC/SW/0010/2015 refers).

6. 15/510589/OUT Outline application for access matters reserved for construction of Business Park (Use Classes B1(B), B1(C), B2 and B8) (research and development, light industrial, general industrial and storage or distribution) (up to a maximum of 46,600sqm), including associated accesses (including alterations to existing northern relief road), parking and servicing areas, landscaping, bunds, surface water storage areas, and related development.

7. 16/501228/FULL Construction of a new baling plant building within an existing waste paper storage yard.

8. 16/501484/COUNTY County matter - The construction and operation of a gypsum recycling building with plant and machinery to recycle plasterboard and the re-configuration of the existing lorry park to include office/welfare facilities and ancillary supporting activities, including rain water harvesting tanks, container storage, new weighbridges, fuel tanks, hardstanding, safe lorry sheeting access platform and automated lorry wash.

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9. 16/506193/ENVSCR EIA Screening Opinion - Outline application for proposed residential development of 275 dwellings including affordable housing with open spaces, appropriate landscaping and minor alterations to the surrounding highway network (access).

10. 17/505073/FULL Erection of a tile factory including service yard, storage yard and car parking area.

11. 18/500257/EIFUL Proposed development of 155 dwellings (9 x 2 bed flats, 13 x 2 bed houses, 66 x 3 bed houses, and 67 x 4 bed houses) together with associated new access road, car parking, linear park with acoustic barrier to the A249, dedicated LEAP, allotments, areas of surface water drainage attenuation and ecological enhancement, and new planting, including an area planted in the style of an orchard.

12. 18/500393/FULL Erection of a natural gas fuelled reserve power plant with a maximum export capacity of up to 12MW

13. 15/502197/FULL Extension to existing yard and HGV parking area including installation of 5 no. lighting columns, landscaping, drainage and amendments to existing balancing pond

14. SW/13/1495 Variation of condition 9 of planning permission SW/11/548 (use of building 15B to install and operate materials recycling facility (MRF) and a refuse derived fuel (RDF) facility and to use existing weighbridge, weighbridge office, site office and washroom/toilets to the south of building 15a) to allow an increase of HGV movements from 58 to 98 (49 in and 49 out) for a temporary period of 12 months

15. 18/502489/FULL Construction of a 7.2m wide internal access road and pedestrian footpath, together with the associated removal of existing water holding lagoon, chemical building and works yard. Erection of a new chemical store, works yard and engine store, breaking out and crushing of existing concrete hardstanding, lighting and landscape planting.

16. EN010090 (18/501923/ADJ) Application for an Order Granting Development Consent to decommission the existing K1 CHP on the site and build, commission and operate a new CHP plant.

17. 15/504458/FULL Formation or new rear access road and extension to trailer park to serve Kemsley Paper Mill and ancillary development including attenuation pond, security kiosk and weightbringers

18. 16/506935/COUNTY County Matters application for steam pipeline connecting the Ridham Dock Biomass Facility to the DS Smith Paper Mill.

19. 17/504034/COUNTY County Matter - Provision of a new car park, drainage layout and SUDs pond to accommodate and support the existing waste management facility

20. SW/14/0191 Extension to existing HGV Fitters shed plus small additional storage building.

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21. 17/502678/COUNTY Section 73 application to vary conditions 15 and 16 of planning permission SW/12/1184 to permit the facility to operate during a wider range of hours and to also change the number of vehicle movements associated with the operations.

22. 17/505919/COUNTY County Matter: For extension of the existing IBA Recycling Facility by the use of an adjoining building and land; and associated amendments to the layout of the site.

23. 17/502834/FULL Installation of new underground water pipeline via open cut trenching and directional auger boring, including working area and site compounds

24. 14/501588/OUT Outline application for the development of 550-600 houses and all necessary supporting infrastructure including roads, open space, play areas, neighbourhood shopping/ community facilities (up to 650 sq m gross) and landscaping. All detailed matters are reserved for subsequent approval except (i) vehicular access to A2 Fox Hill; (ii) emergency access to Peel Drive; (iii) landscape buffer between housing and countryside gap and (iv) layout, planting, biodiversity enhancement and management of countryside gap, as amended by drawings 5257/OPA/SK001 Rev J (new red line plan), D119/52 (Swanstree Avenue Plan) and D119/53 (junction layout plan).

25. 16/507877/FULL Erection of a residential development comprising 383 dwellings including associated access, parking, public open spaces and landscaping. New vehicular/pedestrian access from Eurolink Way and further secondary vehicular/pedestrian access off Crown Quay Lane. Associated drainage and earthworks.

26. 18/502190/EIHYB Full Planning Application - Phase 1 North - Erection of 91 dwellings accessed from Grovehurst Road, public open and amenity space (including an equipped children’s play area) together with associated landscaping and ecological enhancement works, acoustic barrier to the A249, internal access roads, footpaths, cycleways and parking, drainage (including infiltration basins and tanked permeable paving), utilities and service infrastructure works. Full Planning Application - Phase 1 South - Erection of 252 dwellings (including 34 affordable dwellings) accessed from Quinton Road, public open and amenity space, together with associated landscaping and ecological enhancement works, internal access roads, footpaths, cycleways and parking, drainage (including infiltration swales, ring soakaways, and permeable paving), utilities and service infrastructure works. Outline Planning Application - for up to 857 new dwellings (including 10% affordable housing, subject to viability), a site of approximately 10 ha for a secondary and primary school, a mixed use local centre, including land for provision of a convenience store, public open and amenity space (including equipped children’s play areas), together with associated landscaping and ecological enhancement works, acoustic barrier to the A249, internal access roads, footpaths, cycleways and parking, drainage (including a foul water pumping station and sustainable drainage

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systems), utilities and service infrastructure. All matters reserved, except for access for the schools site from Grovehurst Road.

27. 18/503873/ENVSCR EIA Screening Opinion Application for housing and country park

28. 16/507687/COUNTY County matters application for the construction and operation of an Incinerator Bottom Ash (IBA) Recycling Facility on land adjacent to the Kemsley Sustainable Energy Plant

29. 16/507943/FULL Construction of an agricultural anaerobic digestion plant and associated infrastructure, for the purposes of generating renewable energy.

30. SW/13/1571 The erection of four wind turbines with a maximum blade tip height of up to 126.5 metres, together with a substation and control building, associated hardstandings, an improved access junction, connecting internal access tracks, and other related infrastructure.

31. 17/503032/FULL Installation of an electricity battery storage facility within a new steel framed portal building and ancillary infrastructure

32. 15/506005/COUNTY EIA Screening opinion (County) to determine whether an environmental impact assessment is required for the proposed establishment of a secondary aggregate recycling facility and the reworking of existing aggregate deposits at Rushenden Marshes Disposal Site.

33. 16/507594/COUNTY County Matter - phased extraction of brickearth, advance planting, access improvements, restoration and replanting back to agricultural use.

34. 18/503075/NSIP Consultation - Construction and Operation of Photovoltaic (PV) Electricity Generating and Storage.

35. 15/506166/ENVSCR EIA Screening Opinion - Redevelopment of site, comprising demolition of selected buildings, extension, refurbishment and remodelling of selected buildings and the erection of new buildings to provide up to 88,000sqm, comprising laboratories, offices incubation/ innovation hubs; 400sqm of retail and up to 300-400 dwellings.

36. MC/18/2229 request for a screening opinion as to whether an Environmental Impact Assessment is necessary for the development of a new cement plant.

Swale Borough Council Bearing Fruit 2031 Local Plan 2017 Allocations

• A1 Land allocated for 286,200 sqm of ‘B’ class employment uses

• A10 Housing allocations for a mix of at least 240 dwellings

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• A17 Iwade Expansion

• MU1 North West Sittingbourne - minimum of 1,500 dwellings, community facilities and structural landscaping and open space adjacent the A249.

• MU2 mixed use development comprising 43,000 sq m of ‘B’ use class employment uses, approximately 106 dwellings, together with 31.1 ha of open space, flooding, biodiversity and landscape enhancements

• A3 Planning permission will be granted for employment uses (use classes B1, B2 or B8 up to 7,500sqm)

• A4 Planning permission will be granted for employment uses on sites north and south of the A249 at Cowstead Corner, as shown on the Proposals Map. The northern site is allocated for an hotel (use class C1), whilst the southern site for use classes B1, B2 or B8 (5,600sqm).

• MU3 Planning permission will be granted for a minimum of 564 dwellings, commercial floorspace (including potential neighbourhood facilities), landscaping and open space on land at south-west Sittingbourne (Borden),

• MU4 Planning permission will be granted for mixed uses comprising approximately 260 dwellings, 26,840 sqm of ‘B’ use class employment, open space and landscaping

• MU5 Planning permission will be granted for mixed-uses, comprising 1,500 sqm of commercial floorspace, together with some 330 homes and proposals for the conservation, enhancement, and long-term management of the site’s ecological and heritage assets

3.9 General format of the topic chapters

The ES topic chapters herein address each of the environmental issues identified during the scoping process. Each of the topic chapters is structured in general as follows:

• Introduction;

• Legislation and policy (brief summary only);

• Methodology (including standards, guidance and criteria used in the assessment, and any problems experienced);

• Baseline conditions (including identification of sensitive receptors);

• Effects of the K3 Proposed Development during operation, planned maintenance and in the event of any future decommissioning of the facility;

• Mitigation measures;

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• Residual effects;

• Effects of the WKN Proposed Development during construction, operation, planned maintenance and in the event of any future decommissioning of the facility;

• Mitigation measures;

• Residual effects;

• Cumulative effects;

• Summary.

3.10 Assumptions and Limitations

It has been necessary in some instances to make some assumptions in assessing the environmental impact of the K3 and WKN Proposed Developments. In accordance with best practice, the key assumptions are set out below, together with any limitations identified in undertaking this EIA:

• A variety of sources, including historical data, have been used to establish baseline conditions for the purposes of producing technical reports and chapters. These represent a snapshot in time, but aspects of the environment are dynamic and may change before, during and after the construction and operation of the K3 and WKN Proposed Developments. Potential changes have been identified within specific chapters where relevant and possible;

• The design, construction and completed stages of the K3 and WKN Proposed Developments will satisfy minimum environmental standards, consistent with contemporary legislation, practice and knowledge;

• Requirements will be attached to any DCO which control impacts during construction works in the form of a CEMP and will secure any mitigation measures detailed in the ES;

• At this stage the detailed design and construction methods of WKN Proposed Development are not finalised and therefore the EIA assessments have been undertaken on a worst-case basis using maximum parameters. It is assumed that the development will come forward within the parameters set out;

• It is assumed that the technical data provided by the Applicant is a robust and worst-case data set reflective of the K3 and WKN Proposed Developments;

• The K3 and WKN Proposed Developments will be operated in accordance with any IPPC permit issued by the Environment Agency (existing and new) and all contemporary relevant legislation including that as specified in

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section 2.8 of Chapter 2 with regard to health and safety and preventing major accidents and disasters.

Any assumptions relevant to specific topics are set out in the Technical Chapters.

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Legend

K3 Site WKN Site 3KM area Other developments within 3km of the site(s) Local Plan Allocations within 3km of the site(s)

TITLE Figure 3.2a- Cumulative developments within 3Km of the Site(s) CLIENT Wheelabrator Technologies Inc

Job K3 and WKN DCO

SCALE AT A3 DATE JOB NO. 1:25,000 January 2019 13141

Eclipse House, Eclipse Park, Sittingbourne Road Maidstone, Kent ME14 3EN

t: 01622 776226 e: [email protected] w: www.dhaplanning.co.uk

No reproduction by any method of any part of this document Contains OS data © Crown Copyright and database right 2018. Contains public sector information licensed under the Open Government Licence v3.0. is permitted without the consent of the copyright holders. 00.35 0.7 1.4 2.1 Produced for Town and Country planning purposes only. Kilometres O.S Licence Number: AL54535X Legend

K3 WKN 10KM area 3KM area Industrial and Energy developments within 10km of the site(s) Industrial/ Energy/Mixed use Local Plan Allocations within10Km of the site(s)

TITLE Figure 3.2b- Cumulative developments within 10Km of the site(s) CLIENT Wheelabrator Technologies Inc

Job K3 and Wheelabrator Kemsley North

SCALE AT A3 DATE JOB NO. 1:80,000 February 2019 13141

Eclipse House, Eclipse Park, Sittingbourne Road Maidstone, Kent ME14 3EN

t: 01622 776226 e: [email protected] w: www.dhaplanning.co.uk

No reproduction by any method of any part of this document Contains OS data © Crown Copyright and database right 2018. Contains public sector information licensed under the Open Government Licence v3.0. is permitted without the consent of the copyright holders. 00.75 1.5 3 4.5 6 Produced for Town and Country planning purposes only. Kilometres O.S Licence Number: AL54535X

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5 Air Quality

5.1 Introduction

This Chapter assesses the likely significant air quality effects resulting from the K3 and WKN Proposed Developments.

5.2 Regulatory and Policy Framework

There are three main aspects to the regulatory framework affecting potentially- polluting developments; the planning process determines whether and where the development can be located; building regulations control the design and construction of developments; and once built, regulation of pollution from the operation of certain prescribed processes is by the Environmental Permitting Regulations or by nuisance provisions for premises not operating prescribed processes. The relevant parts of the framework of pollution regulation, planning policy and relevant guidance are summarised below.

Industrial Emissions Directive Limits

K3 and the WKN Proposed Development has been/will be designed and operated in accordance with the requirements of the Industrial Emissions Directive (2010/75/EU) [Ref 5.1], known hereafter as the IED, which requires adherence to emission limits for a range of pollutants.

Emission limits in the IED are specified in the form of half-hourly mean concentrations; daily-mean concentrations; mean concentrations over a period of between 30 minutes and 8 hours; or, for dioxins and furans, mean concentrations evaluated over a period of between 6 and 8 hours.

For the purposes of this assessment for those pollutants having only one emission limit (for a single averaging period), the K3 and WKN Proposed Developments have been assumed to operate at that limit. Where more than one limit exists for a pollutant, the half-hourly mean emission concentration limit has been used to calculate short-term (less than 24-hour average) peak ground-level concentrations (Scenario 1). The daily mean emission concentration limit has been used for these pollutants to calculate long-term (greater than 24-hour average) mean ground-level concentrations (Scenario 2). The IED emission limit values are provided in Table 5.1.

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Pollutant Scenario 1 Scenario 2 Short-Term Emission Limits Daily-Mean Emission Limits (mg.Nm-3) (mg.Nm-3) Particles 30 10 Hydrogen chloride (HCl) 60 10 Hydrogen fluoride (HF) 4 1

Sulphur dioxide (SO2) 200 50

Nitrogen oxides (NOx) 400 200 Carbon monoxide (CO) - 50 Group 1 metals (a) - 0.05 (d) Group 2 metals (b) - 0.05 (d) Group 3 metals (c) - 0.5 (d) Dioxins and furans - 0.0000001 (e) Table 5.1: Relevant Industrial Emission Directive Limit Values

The following notes accompany Table 5.1:

• All concentrations referenced to temperature 273 K, pressure 101.3 kPa, 11% oxygen, dry gas.

• (a) Cadmium (Cd) and thallium (Tl).

• (b) Mercury (Hg).

• (c) Antimony (Sb), arsenic (As), lead (Pb), chromium (Cr), cobalt (Co), copper (Cu), manganese (Mn), nickel (Ni), and vanadium (V).

• (d) All average values over a sample period of a minimum of 30 minutes and a maximum of 8 hours.

• (e) Average values over a sample period of a minimum of 6 hours and a maximum of 8 hours. The emission limit value refers to the total concentration of dioxins and furans calculated using the concept of toxic equivalence (TEQ).

Ammonia (NH3), polychlorinated biphenyls (PCBs) and polycyclic aromatic hydrocarbons (PAHs) are not specifically regulated under the IED. For the purposes of this assessment, the emission concentrations in Table 5.2 have been used for these pollutants to calculate long-term (greater than 24-hour average) mean ground-level concentrations (Scenario 2).

Pollutant Scenario 2 Emission Concentrations (mg.Nm-3) NH3 5 PCBs 0.005 PAHs (as B[a]P equivalent) 0.001

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Table 5.2 Modelled Emission Concentrations for non-IED Regulated Pollutants

The following notes accompany Table 5.2:

• All concentrations referenced to temperature 273 K, pressure 101.3 kPa, 11% oxygen, dry gas.

• Emission limits obtained from the IPPC Reference Document on the Best Available Techniques for Waste Incineration (August 2006)

Waste Framework Directive

Directive 2008/98/EC of the European Parliament and Council on Waste requires member states to ensure that waste is recovered or disposed of without harm to human health and the environment. It requires member states to impose certain obligations on all those dealing with waste at various stages. Operators of waste disposal and recovery facilities are required to obtain a permit or register a permit exemption. Retention of the permit requires periodic inspections and documented evidence of the activities in respect of waste.

The Waste Framework Directive (WFD) requires member states to take appropriate measures to establish an integrated and adequate network of disposal installations. The WFD also promotes environmental protection by optimising the use of resources, promoting the recovery of waste over its disposal (the “waste hierarchy”).

Annex I and II of the WFD provide lists of the operations which are deemed to be “disposal” and “recovery”, respectively. The terms are mutually exclusive, and an operation cannot be a disposal and recovery operation simultaneously. Where the operation is deemed to be a disposal operation, the permit will contain more extensive conditions than for a recovery operation.

The principal objective of a recovery operation is to ensure that the waste serves a useful purpose, replacing other substances which would have been used for that purpose. Where the combustion of waste is used to provide a source of energy, the operation is deemed to be a recovery operation.

The proposed development is deemed to be a recovery operation on the basis that the operation falls under the description of the first operation listed under Annex II:

“R 1 Use principally as a fuel or other means to generate energy”

The Environmental Permitting Regulations 2016 (EPR) [Ref 5.2] implement the WFD in the UK. As such, the EA is responsible for implementing the obligations set out in the WFD.

Ambient Air Quality Criteria

There are several EU Air Quality Directives and UK Air Quality Regulations [Ref 5.3] that will apply to the operation of the K3 and WKN Proposed Developments. These provide a series of statutory air quality limit values, target values and objectives for pollutants, emissions of which are regulated through the IED. Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 5-3

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There are some pollutants whose emission levels are regulated by the IED but which do not have statutory ambient air quality standards prescribed under current legislation. For these pollutants, a number of non-statutory ambient air quality objectives and guidelines exist which have been applied within this assessment. The EA provides further assessment criteria in its online guidance.

Air Quality Directive and Air Quality Standards Regulations

The 2008 Ambient Air Quality Directive (2008/50/EC) [Ref 5.4] aims to protect human health and the environment by avoiding, reducing or preventing harmful concentrations of air pollutants; it sets legally binding concentration-based limit values, as well as target values. There are also information and alert thresholds for reporting purposes. These are to be achieved for the main air pollutants: particulate matter (PM10 and PM2.5), nitrogen dioxide (NO2), sulphur dioxide (SO2), ozone (O3), carbon monoxide (CO), lead (Pb) and benzene. This Directive replaced most of the previous EU air quality legislation and in England was transposed into domestic law by the Air Quality Standards (England) Regulations 2010 [Ref 5.3], which in addition incorporates the 4th Air Quality Daughter Directive (2004/107/EC) that sets targets for ambient air concentrations of certain toxic heavy metals (arsenic, cadmium and nickel) and polycyclic aromatic hydrocarbons (PAHs). Member states must comply with the limit values (which are legally binding on the Secretary of State) and the Government and devolved administrations operate various national ambient air quality monitoring networks to measure compliance and develop plans to meet the limit values. The statutory ambient limit values are listed in Table 5.3.

Pollutant Averaging Period Limit Values Not to be Exceeded More Than Nitrogen 1 hour 200 μg.m-3 18 times pcy Dioxide (NO ) 2 Annual 40 μg.m-3 - Particulate 24 hour 50 μg.m-3 35 times pcy Matter (PM ) 10 Annual 40 μg.m-3 - Particulate Annual 25 μg.m-3 - Matter (PM2.5) Carbon Monoxide Maximum daily running 10,000 μg.m-3 - 8 hour mean Sulphur Dioxide 15 minute 266 μg.m-3 > 35 times pcy (SO ) 2 1 hour 350 μg.m-3 > 24 times pcy 24 hour 125 μg.m-3 > 3 times pcy Lead Annual 0.25 μg.m-3 - Arsenic (As) Annual 0.006 μg.m-3 - Cadmium (Cd) Annual 0.005 μg.m-3 - Nickel (Ni) Annual 0.02 μg.m-3 - Table 5.3 Statutory Air Quality Limit Values

Non-Statutory Air Quality Objectives and Guidelines

The Environment Act 1995 established the requirement for the Government and the devolved administrations to produce a National Air Quality Strategy (AQS) for improving ambient air quality, the first being published in 1997 and has been

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revised several times since, with the latest published in 2007 [Ref 5.5]. The Strategy sets UK air quality standards and objectives for the pollutants in the Air Quality Standards Regulations plus 1,3-butadiene and recognises that action at national, regional and local level may be needed, depending on the scale and nature of the air quality problem. There is no legal requirement to meet objectives set within the UK AQS except where equivalent limit values are set within the EU Directives.

The 1995 Environment Act also established the UK system of Local Air Quality Management (LAQM), that requires local authorities to go through a process of review and assessment of air quality in their areas, identifying places where objectives are not likely to be met, then declaring Air Quality Management Areas (AQMAs) and putting in place Air Quality Action Plans to improve air quality. These plans also contribute, at local level, to the achievement of EU limit values.

Non-statutory ambient air quality objectives and guidelines also exist within the World Health Organisation Guidelines [Ref 5.6] and the Expert Panel on Air Quality Standards Guidelines (EPAQS) [Ref 5.7]. The non-statutory ambient objectives and guidelines are presented in Table 5.4.

Pollutant Averaging Period Guideline Target Date

Target of 15% reduction in Between 2010 and Particulate Matter Annual concentrations at urban 2020 (a) (PM2.5) background locations Annual 25 μg.m-3 2020 (a) PAHs (as B[a]P Annual (a) 0.00025 μg.m-3 - equivalent) Sulphur Dioxide Annual (b) 50 µg.m-3 - (SO2) Hydrogen Chloride 1 hour (c) 750 µg.m-3 - Hydrogen Fluoride 1 hour (c) 160 µg.m-3 - Table 5.4: Non-Statutory Air Quality Objectives and Guidelines

The following notes accompany Table 5.4:

• (a) Target date set in UK Air Quality Strategy 2007

• (b) World Health Organisation Guidelines

• (c) EPAQS recommended guideline values

Environmental Assessment Levels

The EA online guidance entitled ‘Environmental management – guidance, Air emissions risk assessment for your environmental permit’ [Ref 5.8] provides further assessment criteria in the form of Environmental Assessment Levels (EALs).

Table 5.5 presents all available EALs for ambient concentrations of the pollutants relevant to this assessment.

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Pollutant Long-term EAL, μg.m-3 Short-term EAL, μg.m-3

Nitrogen dioxide (NO2) 40 (a) 200 Carbon monoxide (CO) - 10,000 Sulphur dioxide (SO2) 50 267 Particulates (PM10) 40 (a) 50 Particulates (PM2.5) 25 - Hydrogen chloride (HCl) - 750 Hydrogen fluoride (HF) 16 (monthly average) 160 Arsenic (As) 0.003 - Antimony (Sb) 5 150 Cadmium (Cd) 0.005 - Chromium (Cr) 5 150 Chromium VI (oxidation 0.0002 - state in the PM10 fraction) Cobalt (Co) 0.2 (a) 6 (a) Copper (Cu) 10 200 Lead (Pb) 0.25 - Manganese (Mn) 0.15 1500 Mercury (Hg) 0.25 7.5 Nickel (Ni) 0.02 - Thallium (Tl) 1 (a) 30 (a) Vanadium (V) 5 1 PAHs (as B[a]P equivalent) 0.00025 - Ammonia 5 - Table 5.5: Environmental Assessment Levels (EALs)

In Table 5.5, (a) refers to EALs obtained from the EA’s earlier Horizontal Guidance Note EPR H1 guidance note [Ref 5.9], as no levels are provided in the current guidance.

Within the assessment, the statutory ambient air quality limit and target values (as presented in Table 5.3) are assumed to take precedent over objectives, guidelines and the EALs. In addition, for those pollutants which do not have any statutory air quality standards, the assessment assumes the lower of either the EAL or the non-statutory air quality objective or guideline where they exist.

Environmental Protection Legislation

Environmental Permitting

Certain industrial installations are regulated under the Environmental Permitting Regulations (England and Wales) Regulations 2016, which implement the EU Directive 2008/1/EC concerning Integrated Pollution Prevention and Control (“the IPPC Directive”). The EPR define activities that require the operator to obtain an Environmental Permit from the EA.

EPR is a regulatory system to control the environmental and health impacts across all environmental media (using an integrated approach) of certain listed industrial activities, via a single permitting process. To gain a permit, operators have to demonstrate in their applications, in a systematic way, that the techniques they are using or are proposing to use for their installation are the Best Available Techniques (BAT) to prevent or minimise the effects of the activity on air, land and water taking account of relevant local factors. The permitting process also places a duty on the regulating body to ensure that the requirements of the IPPC Directive are included for permitted sites to which these apply.

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It is a mandatory requirement of EPR that the Agency ensures that no single industrial installation regulated is the sole cause of a breach of a UK air quality objective. Additionally, the Agency has committed to guarantee that no installation will contribute significantly to a breach of a UK air quality objective.

To do this the Agency will ensure that BAT is used to deliver the maximum improvements to air quality where UK air quality objectives are in danger of being breached.

Section 5.2 of the Overarching National Policy Statement for Energy (EN-1) Air quality and emissions sets out the potential impacts associated with infrastructure development, what should be included in an ES and the role of the IPC in decision making and mitigation. It states “The ES should describe:

• any significant air emissions, their mitigation and any residual effects distinguishing between the project stages and taking account of any significant emissions from any road traffic generated by the project;

• the predicted absolute emission levels of the proposed project, after mitigation methods have been applied;

• existing air quality levels and the relative change in air quality from existing levels; and

• any potential eutrophication impacts.”

Planning Policies

National Policy Statements (NPS)

• the predicted absolute emission levels of the proposed project, after mitigation methods have been applied;

• existing air quality levels and the relative change in air quality from existing levels; and

• any potential eutrophication impacts.”

National Planning Policy Framework (NPPF)

The NPPF sets out three overarching objectives to achieve sustainable development. The relevant objective in the context of this air quality assessment is:

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“an environmental objective – to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution and adapting to climate change, including moving to a low carbon economy” (Paragraph 8c)

Under the heading ‘Promoting sustainable transport’, the NPPF states:

“The planning system should actively manage patterns of growth in support of these objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, and improve air quality and public health. However, opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision-making.” (Paragraph 103)

Under the heading ‘Conserving and enhancing the natural environment’, the NPPF states:

Planning policies and decisions should contribute to and enhance the natural and local environment by:

e) Preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans; …” (Paragraph 170)

“Planning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas. Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement. So far as possible these opportunities should be considered at the plan-making stage, to ensure a strategic approach and limit the need for issues to be reconsidered when determining individual applications. Planning decisions should ensure that any new development in Air Quality Management Areas and Clean Air Zones is consistent with the local air quality action plan.” (Paragraph 181)

National Planning Practice Guidance (NPPG)

The NPPG was issued on-line in March 2014 and is updated periodically by government as a live document. The Air Quality section of the NPPG describes the circumstances when air quality, odour and dust can be a planning concern, requiring assessment.

The NPPG advises that whether or not air quality is relevant to a planning decision will depend on the proposed development and its location. Concerns could arise if the development is likely to generate air quality impact in an area where air quality is known to be poor. They could also arise where the development is likely

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to adversely impact upon the implementation of air quality strategies and action plans and/or, in particular, lead to a breach of EU legislation (including that applicable to wildlife).

The NPPG states that when deciding whether air quality is relevant to a planning application, considerations could include whether the development would:

• “Significantly affect traffic in the immediate vicinity of the proposed development site or further afield. This could be by generating or increasing traffic congestion; significantly changing traffic volumes, vehicle speed or both; or significantly altering the traffic composition on local roads. Other matters to consider include whether the proposal involves the development of a bus station, coach or lorry park; adds to turnover in a large car park; or result in construction sites that would generate large Heavy Goods Vehicle flows over a period of a year or more.

• Introduce new point sources of air pollution. This could include furnaces which require prior notification to local authorities; or extraction systems (including chimneys) which require approval under pollution control legislation or biomass boilers or biomass-fuelled CHP plant; centralised boilers or CHP plant burning other fuels within or close to an air quality management area or introduce relevant combustion within a Smoke Control Area;

• Expose people to existing sources of air pollutants. This could be by building new homes, workplaces or other development in places with poor air quality.

• Give rise to potentially unacceptable impact (such as dust) during construction for nearby sensitive locations.

• Affect biodiversity. In particular, is it likely to result in deposition or concentration of pollutants that significantly affect a European-designated wildlife site and is not directly connected with or necessary to the management of the site, or does it otherwise affect biodiversity, particularly designated wildlife sites.”

The NPPG provides advice on how air quality impacts can be mitigated and notes “Mitigation options where necessary will be locationally specific, will depend on the proposed development and should be proportionate to the likely impact. It is important therefore that local planning authorities work with applicants to consider appropriate mitigation to ensure the new development is appropriate for its location and unacceptable risks are prevented. Planning conditions and obligations can be used to secure mitigation where the relevant tests are met.”

Swale Borough Council’s Development Plan

The Bearing Fruits 2031: The Swale Borough Local Plan was formally adopted by the council on 26 July 2017. In relation to air quality, the plan states that “Transport and industry are the Borough's main air pollution emitters”. It refers to the need for assessment where developments could have an impact on air quality levels within the AQMAs.

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There are no specific policies in the plan guiding industrial development in relation to air quality impacts; the policies generally focus on managing and controlling the impacts of development arising from traffic emissions. In particular, in relation to managing traffic impacts, policy DM6 states that air quality management and environmental quality should be integrated “into the location and design of, and access to, development and, in so doing, demonstrate that proposals do not worsen air quality to an unacceptable degree especially taking into account the cumulative impact of development schemes within or likely to impact on Air Quality Management Areas”.

In the case, the key pollutants from the development are oxides of nitrogen which are also a key concern for traffic emissions. While policy DM6 is not strictly relevant to this development, the assessment has regard for the cumulative impact of the development on the surrounding area including the designated AQMAs.

5.3 Methodology

Scoping and Consultation

The formal scoping exercise is summarised in Chapter 3.

Neither the NPPF, the NPS nor the NPPG is prescriptive on the methodology for assessing air quality effects or describing significance; practitioners use guidance provided by Defra and non-governmental organisations, including Environmental Protection UK (EPUK) and the Institute of Air Quality Management (IAQM). However, the NPPG does advise that:

“Assessments should be proportionate to the nature and scale of development proposed and the level of concern about air quality, and because of this are likely to be locationally specific. The scope and content of supporting information is therefore best discussed and agreed between the local planning authority and applicant before it is commissioned.”

It lists a number of areas that might be usefully agreed at the outset.

This air quality assessment covers the elements recommended in the NPPG. The approach is consistent with the EPUK & IAQM Land-Use Planning & Development Control: Planning For Air Quality document [Ref 5.10], the IAQM Guidance on the assessment of dust from demolition and construction [Ref 5.11] and, where relevant, Defra’s Local Air Quality Management Technical Guidance: LAQM.TG16 [Ref 5.12]. It includes the key elements listed below:

• Establishing the background Ambient Concentration (AC).

• Qualitative assessment of likely construction-phase impacts with mitigation and controls in place.

• Quantitative assessment of the effects from the completed development on local air quality from stack emissions utilising a “new generation” Gaussian dispersion model, ADMS 5. The assessment has considered both the Process Contributions (PC) from the facility in isolation, and the resultant Predicted Environmental Concentrations (PEC) that includes the AC. Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 5-10

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Air quality guidance advises that the organisation engaged in assessing the overall risks should hold relevant qualifications and/or extensive experience in undertaking air quality assessments. The RPS air quality team members involved at various stages of this assessment have professional affiliations that include Fellow and Member of the Institute of Air Quality Management, Chartered Chemist, Chartered Scientist, Chartered Environmentalist and Member of the Royal Society of Chemistry and have the required academic qualifications for these professional bodies. In addition, the Director responsible for authorising all deliverables has over 20 years’ experience.

Establishing Baseline Conditions

In urban areas, pollutant concentrations are primarily determined by the balance between pollutant emissions that increase concentrations, and the ability of the atmosphere to reduce and remove pollutants by dispersion, advection, reaction and deposition. An atmospheric dispersion model is a practical way to simulate these complex processes; such a model requires a range of input data, which can include emissions rates, meteorological data and local topographical information. The model used and the input data relevant to this assessment are described in the following sections.

The atmospheric pollutant concentrations depend not only on local sources, but also on regional pollution and pollution from more remote sources brought in on the incoming air mass. This background contribution needs to be added to the fraction from the modelled sources and is usually obtained from measurements or estimates of urban background concentrations for the area in locations that are not directly affected by local emissions sources.

Where it has been necessary to consider background pollution levels, these have been derived from consideration of Air Quality Review & Assessment findings and assessment of existing local air quality through a review of available air quality monitoring and Defra background map data in the vicinity of the K3/WKN Sites.

Assessment of Effects

This assessment covers the WKN and K3 Proposed Developments including all works (No 1-7) set out in Chapter 2.

Construction Phase

Dust is the generic term used to describe particulate matter in the size range 1- 75 µm in diameter [Ref 5.12]. Particles greater than 75 µm in diameter are termed grit rather than dust. Dusts can contain a wide range of particles of different sizes. The normal fate of suspended (i.e. airborne) dust is deposition. The rate of deposition depends largely on the size of the particle and its density; together these influence the aerodynamic and gravitational effects that determine the distance it travels and how long it stays suspended in the air before it settles out onto a surface. In addition, some particles may agglomerate to become fewer, larger particles; whilst others react chemically.

The effects of dust are linked to particle size and two main categories are usually considered:

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PM10 particles, those up to 10 µm in diameter, remain suspended in the air for long periods and are small enough to be breathed in and so can potentially impact on health; and

Dust, generally considered to be particles larger than 10 µm which fall out of the air quite quickly and can soil surfaces (e.g. a car, window sill, laundry). Additionally, dust can potentially have adverse effects on vegetation and fauna at sensitive habitat sites.

The IAQM Guidance on the assessment of dust from demolition and construction [Ref 5.11] sets out 350 m as the distance from the site boundary and 50 m from the site traffic route(s) up to 500 m of the entrance, within which there could potentially be nuisance dust and PM10 effects on human receptors. For sensitive ecological receptors, the corresponding distances are 50 m in both cases. (In this particular application, there are no ecological receptors within the distances and ecological effects have been scoped out). These distances are set to be deliberately conservative. These distances are set to be deliberately conservative.

Concentration-based limit values and objectives have been set for the PM10 suspended particle fraction, but no statutory or official numerical air quality criterion for dust annoyance has been set at a UK, European or World Health Organisation (WHO) level. Construction dust assessments have tended to be risk based, focusing on the appropriate measures to be used to keep dust impacts at an acceptable level.

The IAQM dust guidance aims to estimate the impacts of both PM10 and dust through a risk-based assessment procedure. The IAQM dust guidance document states: “The impacts depend on the mitigation measures adopted. Therefore, the emphasis in this document is on classifying the risk of dust impacts from a site, which will then allow mitigation measures commensurate with that risk to be identified.”

The IAQM dust guidance provides a methodological framework but notes that professional judgement is required to assess effects: “This is necessary, because the diverse range of projects that are likely to be subject to dust impact assessment means that it is not possible to be prescriptive as to how to assess the impacts. Also, a wide range of factors affect the amount of dust that may arise, and these are not readily quantified.”

Consistent with the recommendations in the IAQM dust guidance, a risk-based assessment has been undertaken for the development, using the well-established source-pathway-receptor approach:

The dust impact (the change in dust levels attributable to the development activity) at a particular receptor will depend on the magnitude of the dust source and the effectiveness of the pathway (i.e. the route through the air) from source to receptor.

The effects of the dust are the results of these changes in dust levels on the exposed receptors, for example annoyance or adverse health effects. The effect experienced for a given exposure depends on the sensitivity of the particular receptor to dust. An assessment of the overall dust effect for the area as a whole has been made using professional judgement taking into account both the change

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in dust levels (as indicated by the Dust Impact Risk for individual receptors) and the absolute dust levels, together with the sensitivities of local receptors and other relevant factors for the area.

The detail of the dust assessment methodology is provided in Appendix 5.1.

The assessment methodology does not consider the air quality impacts of dust from any contaminated land or buildings; the issue of contamination is dealt with in Chapter 9: Ground Conditions.

Decommissioning Phase

The risk of dust impacts during the decommissioning phase, including demolition, will be the same or similar to the risk of impacts during the construction phase. A Demolition Construction Management Plan will be produced prior to decommissioning.

Decommissioning-related traffic is expected to be lower than the construction phase and the impacts of decommissioning-vehicle exhaust emissions have not been assessed specifically. The impact of construction-vehicle exhaust emissions is considered to be negligible and therefore the impacts of decommissioning- vehicle exhaust emissions is also considered to be negligible.

Operation of the K3 and WKN Proposed Developments

Summary of Key Pollutants Considered

The following effects have been assessed in this Chapter.

• Residual emissions from the flue gas treatment system and their effects on human health and ecological receptors

• Fugitive emissions of dust, odour and bio-aerosols during the operational phase

• Emissions from vehicle movements generated by the operation of the developments.

The assessment methodology for the stack emissions are described in the following sections. The assessment methodology for vehicle emissions is described in Appendix 5.5.

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Dispersion Model Selection A number of commercially available dispersion models are able to predict ground level concentrations arising from emissions to atmosphere from elevated point sources. Modelling for this study has been undertaken using ADMS 5, a version of the ADMS (Atmospheric Dispersion Modelling System) developed by Cambridge Environmental Research Consultants (CERC) that models a wide range of buoyant and passive releases to atmosphere either individually or in combination. The model calculates the mean concentration over flat terrain and also allows for the effect of plume rise, complex terrain, buildings and deposition. Dispersion models predict atmospheric concentrations within a set level of confidence and there can be variations in results between models under certain conditions; the ADMS 5 model has been formally validated and is widely used in the UK and internationally for regulatory purposes.

ADMS comprises a number of individual modules each representing one of the processes contributing to dispersion or an aspect of data input and output. Amongst the features of ADMS are:

• An up-to-date dispersion model in which the boundary layer structure is characterised by the height of the boundary layer and the Monin-Obukhov length, a length scale dependent on the friction velocity and the heat flux at the surface. This approach allows the vertical structure of the boundary layer, and hence concentrations, to be calculated more accurately than does the use of Pasquill-Gifford stability categories, which were used in many previous models (e.g. ISCST3). The restriction implied by the Pasquill-Gifford approach that the dispersion parameters are independent of height is avoided. In ADMS the concentration distribution is Gaussian in stable and neutral conditions, but the vertical distribution is non-Gaussian in convective conditions, to take account of the skewed structure of the vertical component of turbulence;

• A number of complex modules including the effects of plume rise, complex terrain, coastlines, concentration fluctuations and buildings; and

• A facility to calculate long-term averages of hourly mean concentration, dry and wet deposition fluxes and radioactivity, and percentiles of hourly mean concentrations, from either statistical meteorological data or hourly average data.

Meteorological Data The most important meteorological parameters governing the atmospheric dispersion of pollutants are wind direction, wind speed and atmospheric stability as described below:

• Wind direction determines the sector of the compass into which the plume is dispersed;

• Wind speed affects the distance that the plume travels over time and can affect plume dispersion by increasing the initial dilution of pollutants and inhibiting plume rise; and

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• Atmospheric stability is a measure of the turbulence of the air, and particularly of its vertical motion. It therefore affects the spread of the plume as it travels away from the source. New generation dispersion models, including ADMS, use a parameter known as the Monin-Obukhov length that, together with the wind speed, describes the stability of the atmosphere.

For meteorological data to be suitable for dispersion modelling purposes, a number of meteorological parameters need to be measured on an hourly basis. These parameters include wind speed, wind direction, cloud cover and temperature. There are only a limited number of sites where the required meteorological measurements are made.

The year of meteorological data that is used for a modelling assessment can have a significant effect on source contribution concentrations. Dispersion model simulations have been performed using five years of data from Gravesend between 2012 and 2016.

Wind roses have been produced for each of the years of meteorological data used in this assessment and are presented in Figure 5.1.

Surface Roughness The roughness of the terrain over which a plume passes can have a significant effect on dispersion by altering the velocity profile with height, and the degree of atmospheric turbulence. This is accounted for by a parameter called the surface roughness length.

A surface roughness length of 0.5 m has been used within the model to represent the average surface characteristics across the study area.

Terrain A complex terrain file has been included within the model to ensure that the relative height between receptors and the source of emissions is taken into account.

Building Wake Effects The movement of air over and around buildings generates areas of flow circulation, which can lead to increased ground level concentrations in the building wakes. Where building heights are greater than about 30 - 40% of the stack height, downwash effects can be significant. Chapter 2 provides a site layout plan. The buildings associated with the Proposed Development that have been included within the model are provided in Table 5.6. The predictions presented in this report therefore include building wake effects.

The exact locations of the stack and building dimensions for WKN are not fixed; however, where possible, worse case assumptions have been made. For example, the dimensions presented in Table 5.6 include a +10% buffer. If the buildings are smaller than this then the predicted concentrations are likely to be lower. The assessment therefore presents the worst case in terms of building wake effects.

There is potential for the location of all buildings for WKN to vary by 5 m. Downwash effects caused by buildings near the stack can affect ground level

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concentrations. Low pressure on the leeward side of buildings can bring the plume to the ground closer than would be the case for no building. The impact of a change in building locations will be a change in the location of the maximum impact over the short-term, rather than a significant change in the magnitude of the maximum prediction. Similarly, slight variations in the stack locations are more likely to affect the location of maximum impact rather than the magnitude. On that basis movement of the buildings by up to 5m is not expected to be significant.

Building Name Approx. location of Length Width Height centre (x,y) (m) (m) (m) Air Cooled Condenser 592098, 166589 29 80 27 Turbine Hall 592150, 166634 40 27 23 Flue Gas Treatment 592166, 166599 16 44 23 K3 Proposed Flue Gas Treatment 592181, 166615 24 43 31 Development Boiler Hall 592192, 166639 30 61 50 Bunker Hall 592223, 166662 40 72 36 Tipping Hall 592253, 166692 46 51 21 Bottom Ash Hall 592193, 166697 16 32 21 FGT 592066, 166715 45 35 30 Substation 592043, 166665 30 45 7 ACC 592076, 166680 45 30 25 Stores next to Pond 592234, 166775 35 40 10 WKN Admin 592172, 166715 15 30 25 Proposed Turbine 592145, 166706 20 35 20 Development Stores next to Turbine 592123, 166702 10 20 10 Boiler 592118, 166727 43 36 43 Bunker 592155, 166737 35 36 30 Tipping Hall 592192, 166745 45 36 20 Table 5.6 Buildings Included Within the Model

Stack Parameters and Emissions Rates Used in Model Stack and emissions characteristics modelled are provided in Table 5.7. For the purposes of modelling, it has been assumed that pollutant emission concentrations are at the limit set in the IED. As this is the maximum concentration that could be permitted, this is a worst-case assumption. The locations of the stacks are shown in Figure 5.2.

Parameter Unit K3 as consented K3 Proposed WKN Proposed Development Development Grid x,y 592135, 166569 592135, 166569 592043, 166710 coordinates Stack height m 90 90 90

Internal m 3.25 3.25 4.0 diameter Efflux m.s-1 19.06 22.81 15.3 velocity Efflux oC 140 140 130 temperature Actual m3.s-1 158.42 189.2 192.3 Volumetric flow

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Parameter Unit K3 as consented K3 Proposed WKN Proposed Development Development O2 % 8.1 8.1 8 Water % 17.8 17.8 19 Normalised Nm3.s-1 110.98 132.9 137.5 Volumetric Flow (00C, dry, 11% O2) Short Long Short Long Short Long Pollutants

g.s-1 3.33 1.11 3.99 1.33 4.12 1.37 Particles

g.s-1 6.66 1.11 7.98 1.33 8.25 1.37 HCl

g.s-1 0.44 0.11 0.53 0.13 0.55 0.14 HF

g.s-1 22.20 5.55 26.59 6.65 27.49 6.87 SO2

g.s-1 44.39 22.20 53.18 26.59 54.99 27.49 NOx

g.s-1 11.10 5.55 13.29 6.65 13.75 6.87 CO

Group 1 g.s-1 - 5.55E-03 - 6.65E-03 - 6.87E-03 Metals Total (b) Group 2 g.s-1 - 5.55E-03 - 6.65E-03 - 6.87E-03 Metals (c) Group 3 g.s-1 - 5.55E-02 - 6.65E-02 - 6.87E-02 Metals Total (d) Dioxins and g.s-1 - 1.11E-08 - 1.33E-08 - 1.37E-08 furans g.s-1 - 5.55E-04 - 6.65E-04 - 6.87E-04 PCBs

PAHs – g.s-1 - 1.11E-04 - 1.33E-04 - 1.37E-04 B[a]P g.s-1 - 5.55E-01 - 6.65E-01 - 6.87E-01 NH3

Table 5.7 Stack and Emissions Characteristics – Main Stacks

Modelled Scenarios The K3 Proposed Development has been modelled and compared with the future baseline (i.e. K3 operating in accordance with its existing planning consent) to demonstrate the practical effect of the K3 Proposed Development.

For WKN, the model has been used to predict the PC for the following scenarios:

• WKN Proposed Development;

• WKN Proposed Development and K3 as consented; and

• WKN Proposed Development and K3 Proposed Development.

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Stack Height Determination There is a need to discharge the flue gases through an elevated stack to allow dispersion and dilution of the residual combustion emissions. The stack needs to be of sufficient height to ensure that pollutant concentrations are acceptable by the time they reach ground level. The stack also needs to be high enough to ensure that releases are not within the aerodynamic influence of nearby buildings, or else wake effects can quickly bring the undiluted plume down to the ground.

A stack height determination has been undertaken to identify the stack height required to overcome the wake effects of nearby buildings and to establish the height at which there is minimal additional environmental benefit associated with the cost of further increasing the stack. The EA removed its detailed guidance, Horizontal Guidance Note EPR H1 [Ref 5.9], for undertaking risk assessments on 1 February 2016; however, in the absence of any other guidance, the approach used here by RPS is consistent with that EA guidance which required the identification of “an option that gives acceptable environmental performance but balances costs and benefits of implementing it.”

The stack height determination involved running a series of atmospheric dispersion modelling simulations to predict the ground-level concentrations with the stack at different heights. The results of the stack height determination for the WKN Proposed Development are provided in Appendix 5.2. For K3 a stack height determination was undertaken in the 2010 ES (see Document 3.3 submitted in support of the application).

NOx to NO2 Assumptions for Annual-Mean Calculations

Total conversion (i.e. 100%) of NO to NO2 is sometimes used for the estimation of the absolute upper limit of the annual mean NO2. This technique is based on the assumption that all NO emitted is converted to NO2 before it reaches ground level. However, in reality the conversion is an equilibrium reaction and even at ambient concentrations a proportion of NOx remains in the form of NO. Total conversion is, therefore, an unrealistic assumption, particularly in the near field [Ref 5.15]. While this approach is useful for screening assessments, it is not appropriate for detailed assessments.

Historically, the EA has recommended that for a ‘worse case scenario’, a 70% conversion of NO to NO2 should be considered for calculation of annual average concentrations. If a breach of the annual average NO2 objective/limit value occurs, the EA requires a more detailed assessment to be carried out with operators asked to justify the use of percentages lower than 70%.

Following the withdrawal of the EA’s H1 guidance document, there is no longer an explicit recommendation; however, for the purposes of this detailed assessment, a 70% conversion of NO to NO2 has been assumed for annual average NO2 concentrations in line with the EA’s historic recommendations.

NOx to NO2 Assumptions for Hourly-Mean Calculations An assumed conversion of 35% follows the EA’s recommendations [Ref 5.16] for the calculation of ‘worse case’ scenario short-term NO2 concentrations.

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Modelling of Long-term and Short-term Emissions

Long-term (annual-mean) NO2 has been modelled for comparison with the relevant annual mean objectives.

For short-term NO2, the objective is for the hourly-mean concentration not to exceed 200 μg.m-3 more than 18 times per calendar year. As there are 8,760 hours in a non-leap year, the hourly-mean concentration would need to be below 200 μg.m-3 in 8,742 hours, i.e. 99.79% of the time. Therefore, the 99.79th percentile of hourly NO2 has been modelled.

Significance Criteria

Construction and Decommissioning Phase

Dust impact risk categories have been determined for demolition, earthworks, construction and trackout. These have been used to define the appropriate site- specific mitigation measures based on those described in the IAQM dust guidance. The guidance states that provided the mitigation measures are successfully implemented, the resultant effects of the dust exposure will normally be “not significant”.

Completed Development

The on-line EA guidance for risk assessments [Ref 5.8] provides details for screening out substances for detailed assessment. In particular, it states that:

“To screen out a PC for any substance so that you don’t need to do any further assessment of it, the PC must meet both of the following criteria:

• the short-term PC is less than 10% of the short-term environmental standard

• the long-term PC is less than 1% of the long-term environmental standard

If you meet both of these criteria you don’t need to do any further assessment of the substance.

If you don’t meet them, you need to carry out a second stage of screening to determine the impact of the PEC.”

The PEC refers to the Predicted Environmental Concentration calculated as the PC added to the ambient concentration. The on-line EA guidance continues by stating that:

“You must do detailed modelling for any PECs not screened out as insignificant.”

It then states that further action may be required where:

“your PCs could cause a PEC to exceed an environmental standard (unless the PC is very small compared to other contributors – if you think this is the case contact the EA) the PEC is already exceeding an environmental standard”

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On that basis:

• The impacts are not considered significant if the short-term PC is less than 10 % of the short-term Environmental Assessment Level (EAL);

• The impacts are not considered significant if the long-term PC is less than 1 % of the long-term EAL; or

• The impacts are not considered significant if the PEC is below the EAL.

For the purposes of this assessment, impacts that are not considered significant are described as negligible.

Limitations and Assumptions

All air quality assessment tools, whether models or monitoring measurements, have limitations. The choices that the practitioner makes in setting-up the model, choosing the input data, and selecting the baseline monitoring data will decide whether the final predicted impact should be considered a central estimate, or an estimate tending towards the upper bounds of the uncertainty range (i.e. tending towards worst-case).

The atmospheric dispersion model itself has limitations, due to it being a simplified version of the real situation: it uses a sophisticated set of mathematical equations to approximate the complex physical and chemical atmospheric processes taking place as a pollutant is released and as it travels to a receptor. The predictive ability of even the best model is limited by how well the turbulent nature of the atmosphere can be represented.

Each of the data inputs for the model, listed earlier, will also have some uncertainty associated with them. Where it has been necessary to make assumptions, these have mainly been made towards the upper end of the range informed by an analysis of relevant, available data.

The main components of uncertainty in the total predicted concentrations, made up of the background concentration and the modelled fraction, include those summarised in Table 5.8.

Concentration Source of Approach to Dealing Comments Uncertainty with Uncertainty The background The background concentration used concentration is the major within the assessment is proportion of the total Characterisation of Background the most conservative predicted concentration. current baseline air Concentration value from a comparison The conservative quality conditions of measured and Defra assumptions adopted mapped concentration ensure that the background estimates. concentration used within

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Concentration Source of Approach to Dealing Comments Uncertainty with Uncertainty The future background the model should lead to a concentration used in forecast concentration that the assessment is the is towards the top of the same as the current uncertainty range, rather background than a central estimate. Characterisation of concentration and no future baseline air reduction has been quality (i.e. the air assumed. This is a quality conditions in conservative assumption the future assuming as, in reality, that the background development does concentrations are likely not proceed) to reduce over time as cleaner vehicle technologies form an increasing proportion of the fleet. Uncertainties arise from any differences between the conditions at the met station and the development site, and between the historical met years and the future years. These have been Meteorological Data minimised by using meteorological data collated at a The modelled fraction is representative likely to contribute to the Model measuring site. The result being between a Input/Output model has been run for central estimate and the Data 5 full years of top of the uncertainty meteorological range. conditions. The model has been run for a grid of receptors. In addition, receptor locations have been Receptors identified where

concentrations are highest or where the greatest changes are expected. Table 5.8 Summary of Main Components of Uncertainty

The analysis of the component uncertainties indicates that, notwithstanding the limitations of the assessment, the predicted total concentration is likely to be conservative. The actual concentrations that will be found when the development is completed are unlikely to be higher than those presented within this report and are more likely to be lower.

5.4 Existing Baseline Conditions

The background concentration often represents a large proportion of the total pollution concentration, so it is important that the background concentration selected for the assessment is realistic. The NPPG and EPUK & IAQM guidance highlight public information from Defra and local monitoring studies as potential sources of information on background air quality. LAQM.TG16 [Ref 5.13] Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 5-21

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recommends that Defra mapped concentration estimates are used to inform background concentrations in air quality modelling and states that: “Where appropriate these data can be supplemented by and compared with local measurements of background, although care should be exercised to ensure that the monitoring site is representative of background air quality”.

For this assessment, existing background air quality has been characterised by drawing on information from the following public sources:

• Defra maps [Ref 5.14], which show estimated pollutant concentrations across the UK in 1 km grid squares; and

• Published results of local authority Review and Assessment (R&A) studies of air quality, including local monitoring and modelling studies.

A detailed description of how the baseline air quality has been derived for the key combustion related pollutants (NO2 and PM10) for the K3 and WKN Proposed Developments is summarised in the following paragraphs.

Review and Assessment Process

Swale Borough Council (SBC), has designated four areas as AQMAs due to high levels of NO2 attributable to road traffic:

• AQMA 1 – Newington AQMA, 6 km west of the Site.

• AQMA 2 – Ospinge Street, Faversham, 9.7 km southwest of the Site.

• AQMA 3 – East Street, Sittingbourne, 3 km south of the Site.

• AQMA 4 – St Pauls Street, Sittingbourne, 2.8 km south of the Site.

The Site is not located within a designated AQMA. As such, air quality at the Site is likely to be good.

Local Urban Background Monitoring

Monitors at urban background locations measure concentrations away from the local influence of emission sources. SBC does not operate any continuous automatic instruments in a background location. The nearest continuous automatic monitor in a background location is in the neighbouring borough of Maidstone, approximately 13 km from the Site; the urban background monitor at Chatham Luton was closed in 2014 and the urban background monitor at the Chaucer Technology School in Canterbury is approximately 23 km from the Site, considerably further away than the Maidstone site.

The most recent annual-mean concentrations measured at Maidstone are presented in Table 5.9. Values shown in bold have low data capture.

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Monitor Approx. Pollutant Concentration (μg.m-3) Name Distance 2011 2012 2013 2014 2015 2016 Ave from the Site (km) Maidstone 13 NO2 12.5 13.7 13.5 12.3 12.6 12.0 12.8 (Rural Backgroun d) PM10 15.8 17.5 18.8 25.3 19.0 20 19.4

Table 5.9 Automatically Monitored Urban Background Annual-Mean Concentrations

SBC manually monitors NO2 concentrations at three urban background locations using passive diffusion tubes and the most recently measured annual-mean concentrations are presented in Table 5.10. All concentrations have been adjusted for bias in accordance with good practice.

Approx. Concentration (μg.m-3) Monitor Distance x y Name from the 2011 2012 2013 2014 2015 Ave Site (km) SW34 - Hernehill 6066 15.5 161110 14.9 13.1 11.9 10.0 10.2 12.0 Village 24 Hall SW77 - Kemsley 5910 0.4 166521 32.3 31.3 34.5 30.9 29.7 31.7 Fields, 35 Swale Way SW88 - 5893 Sonara 2.5 165047 - 27.2 24.3 22.3 19.5 23.3 20 Way Table 5.10 Passively Monitored Urban Background Annual-Mean NO2 Concentrations

The existing background concentrations of other pollutants are provided in Appendix 5.3.

Defra Mapped Concentration Estimates

Defra’s total annual-mean NO2 concentration estimates have been collected for the 1 km grid squares of the monitoring sites and the Site. Similarly, Defra’s total annual-mean PM10 concentration estimates have been collected for the 1 km grid square of the Maidstone (rural) monitoring sites and the Site. The concentrations are summarised in Table 5.11 and Table 5.12.

Monitor Name Approx. Concentration (μg.m-3) Distance to Range of Monitored Estimated Defra Site (km) Mapped Maidstone 13.0 12.0 - 13.7 13.6 SW34 -Hernehill Village 15.5 10.0 – 14.9 13.1 Hall SW77 - Kemsley Fields, 0.4 29.7 – 34.5 13.6 Swale Way SW88 - Sonara Way 2.5 19.5 – 27.2 16.2 The Site - - 12.5

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Table 5.11 Defra Mapped Annual-Mean NO2 Concentration Estimates

Monitor Name Approx. Concentration (μg.m-3) Distance to Range of Monitored Estimated Defra Site (km) Mapped Maidstone 13.0 15.8 – 25.3 15.4 The Site - - 15.4

Table 5.12 Defra Mapped Annual-Mean PM10 Concentration Estimates

Appropriate Background Concentrations for the K3/WKN Sites

For NO2, the Defra mapped concentration estimates are within the range of the results from monitoring at the Maidstone continuous automatic monitor and Hernehill Village Hall but below the range at the other closest monitoring location sites, SW77 and SW88, where the Defra mapped concentration estimates are well below the bottom of the measured range. This suggests that the Defra mapped concentration estimate would not be conservative or representative of concentrations at the Site. On that basis, the average of the concentrations monitored at SW77 Kemsley Fields, 31.7 μg.m-3, has been used to inform the existing background annual-mean NO2.

For PM10, the Defra mapped concentration estimate is are below the range of the results from monitoring at the Maidstone continuous automatic monitor suggesting that the Defra mapped concentration estimate would not be conservative or representative of concentrations at the Site. On that basis, the average of the concentrations monitored at Maidstone, 19.4 μg.m-3, has been used to inform the existing background annual-mean PM10 concentration.

Sensitive Receptors

The air quality assessment predicts the impacts at locations that could be sensitive to any changes. For human-health effects, such sensitive receptors should be selected where the public is regularly present and likely to be exposed over the averaging period of the objective. LAQM.TG16 [Ref 5.13] provides examples of exposure locations and these are summarised in Table 5.13.

Averaging Objectives should apply at: Objectives should generally not Period apply at: Annual- All locations where members of the Building façades of offices or other mean public might be regularly exposed. places of work where members of the Building façades of residential public do not have regular access. properties, schools, hospitals, care Hotels, unless people live there as homes. their permanent residence. Gardens of residential properties. Kerbside sites (as opposed to locations at the building’s façades), or any other location where public exposure is expected to be short- term. Daily-mean All locations where the annual-mean Kerbside sites (as opposed to objective would apply, together with locations at the building’s façade), or hotels. any other location where public Gardens of residential properties. exposure is expected to be short- term.

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Averaging Objectives should apply at: Objectives should generally not Period apply at: Hourly- All locations where the annual and Kerbside sites where the public would mean 24-hour mean would apply. Kerbside not be expected to have regular sites (e.g. pavements of busy access. shopping streets).

Those parts of car parks, bus stations and railway stations etc which are not fully enclosed, where members of the public might reasonably be expected to spend one hour or more. Any outdoor locations to which the public might reasonably be expected to spend 1-hour or longer. Table 5.13: Examples of Where Air Quality Objectives Apply

The ground level concentrations have been modelled across a grid of 20 km by 20 km, with a spacing of 200m, centred on the stack.

In addition, the effects of the K3 and WKN Proposed Developments have been assessed at the façades of a representative selection of discrete local existing receptors. All human receptors have been modelled at a height of 1.5 m, representative of typical head height. The locations of these discrete receptors are listed in Table 5.14 and illustrated in Figure 5.2.

Receptor ID Receptor Approx Distance to Site Grid Reference (m) x y R1 Recreation Way 670 591391 166087 R2 Premier Way 970 590967 166509 R3 Grovehurst Road 1,540 590404 166463 R4 Grovehurst Road 1,510 590746 165486 R5 Saffron Way 1,580 590924 165184 R6 Straymarsh Farm 4,200 592706 170419 R7 Wigeon Road 1,790 590368 167295 R8 Howt Green 2,250 589762 165887 R9 Lorimar Court 2,870 589256 165287 R10 Key Street 4,360 588127 164204 R11 Newlands Avenue 3,880 588855 163953 R12 East Street 2,870 591165 163568 R13 Frognam Gardens 4,900 595060 162529 R14 Hartlip Hill 7,600 584437 165225 R15 Rookery Close 6,500 588203 160829 R16 Wren's Hill 8,600 597167 159333 R17 Nunfield House 8,100 584481 163112 R18 Squirrels Farm 9,500 584146 160880 R19 Grovehurst Road 1700 590335 166741 R20 Swale Way 800 591251 166473 Table 5.14: Modelled Sensitive Receptors

The AQS NO2 objectives for all the different averaging periods apply at the façades of the modelled sensitive receptors.

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The receptor points selected for the assessment of sensitive ecological sites are described in Appendix 5.4.

5.5 Assessment baseline

For background traffic-related NO2 concentrations, the view historically has been that in the UK it would reduce over time, due to the progressive introduction of improved vehicle technologies and increasingly stringent limits on emissions. However, the results of recent monitoring across the UK suggest that background annual-mean NO2 concentrations have not decreased in line with expectations. Inspection of the results of local monitoring presented here indicates that there is no particular trend over time for concentrations of NO2 or PM10 in the vicinity of the K3/WKN Sites.

To ensure that the assessment presents conservative results, no reduction in the background has been applied for future years. Table 5.15 summarises the existing annual-mean Ambient Concentrations (AC) for NO2 and PM10. Where short-term background concentrations are required, the annual-mean concentrations have been doubled as is the convention.

Pollutant Data Source Ambient Concentration (μg.m-3)

Long-term Short-term

NO2 SW77 - Kemsley Fields, Swale 31.7 63.4 Way – diffusion tube

PM10 Maidstone - continuous automatic 19.4 - monitor

Table 5.15 Summary of Background Annual-Mean Concentrations used in the Assessment

Where relevant, future baseline concentrations have been calculated at each modelled receptor location (grid points and selected sensitive receptors) as the total of the existing background concentration and the process contribution for the permitted K3. This is described as the Future Ambient Concentration (known hereafter as the Future AC) to distinguish it from the existing Ambient Concentration.

5.6 The K3 Proposed Development

Construction Effects

A construction dust assessment was undertaken as part of the original planning application for the now permitted K3 facility. Mitigation measures were recommended to ensure that the effect from construction would be not significant. (The original assessment is provided as Appendix 2.2. to Chapter 2.) Assuming that these mitigation measures are implemented during the construction phase for K3, the residual effect is expected to be not significant.

The air quality assessment for the permitted K3 did not quantitatively assess the effects of construction traffic on air quality as construction traffic flows were

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expected to be lower than operational traffic flows. The operational traffic flows are considered later in this chapter.

Completed Development Effects

For each of the five years of meteorological data (2012 to 2016), the maximum predicted concentration across the identified selected sensitive receptors has been derived and are reported below. The predicted Process Contribution (PC) is for the K3 Proposed Development.

Scenario 1: Short-Term IED Emission Limit Values

Table 5.16 summarises the maximum predicted PC to ground-level concentrations for all relevant pollutants with short-term emission limit values set out in the IED.

Scenario 2: Long-Term IED Emission Limit Values

Table 5.17 summarises the PCs for all pollutants assuming that the K3 Proposed Development is operating at long-term emission limit values.

Pollutant Averaging Period EAL K3 PC K3 Criteria Is K3 PC (μg.m- (μg.m- PC (%) Potentially 3) 3) as Significant? % of EAL HCl 1 hour (maximum) 750 12.3 2 10 No HF 1 hour (maximum) 160 0.8 1 10 No

SO2 15 minute (99.90th percentile) 266 37.7 14 10 Yes 1 hour (99.73th percentile) 350 30.1 9 10 No 24 hour (99.18th percentile) 125 15.2 12 10 Yes

NO2 1 hour (99.79th percentile) 200 21.9 11 10 Yes

PM10 24 hour (90.41st percentile) 50 0.9 2 10 No CO 8 hour (maximum daily running) 10000 14.2 0 10 No Table 5.16 Predicted Maximum Process Contributions at Short-Term Emission Limit Values – K3

Pollutant Averaging Period EAL K3 PC K3 PC Criteria Is K3 PC (μg.m-3) (μg.m-3) as % of (%) Potentially EAL Significant?

PM10 24 hour (90.41st 50 0.3 1 10 No percentile) 24 hour (annual 40 0.1 0 1 No mean) PM2.5 24 hour (annual 25 0.1 0 1 No mean) HCl 1 hour 750 2.1 0 10 No (maximum) HF 1 hour 160 0.2 0 10 No (maximum) SO2 15 minute 266 9.4 4 10 No (99.90th percentile) 1 hour (99.73th 350 7.5 2 10 No percentile)

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Pollutant Averaging Period EAL K3 PC K3 PC Criteria Is K3 PC (μg.m-3) (μg.m-3) as % of (%) Potentially EAL Significant? 24 hour (99.18th 125 3.8 3 10 No percentile) 1 hour (annual 50 0.5 1 1 No mean) NO2 1 hour (99.79th 200 11.0 5 10 No percentile) 1 hour (annual 40 1.4 3 1 Yes mean) CO 8 hour (maximum 10,000 7.1 0 10 No daily running) Cd 1 hour (annual 0.005 4.95E- 10 10 No mean) 04 Tl 1 hour 30 1.03E-02 0 10 No (maximum) 1 hour (annual 1 4.95E- 0 1 No mean) 04 Hg 1 hour 7.5 1.03E-02 0 10 No (maximum) 1 hour (annual 0.25 4.95E- 0 1 No mean) 04 Sb 1 hour 150 1.03E-01 0 10 No (maximum) 1 hour (annual 5 4.95E- 0 1 No mean) 03 As 1 hour (annual 0.003 4.95E- 165 1 Yes mean) 03 Cr 1 hour 150 1.03E-01 0 10 No (maximum) 1 hour (annual 5 4.95E- 0 1 No mean) 03 Co 1 hour 6 1.03E-01 2 10 No (maximum) 1 hour (annual 0.2 4.95E- 2 1 Yes mean) 03 Cu 1 hour 200 1.03E-01 0 10 No (maximum) 1 hour (annual 10 4.95E- 0 1 No mean) 03 Pb 1 hour (annual 0.25 4.95E- 2 1 Yes mean) 03 Mn 1 hour 1500 1.03E-01 0 10 No (maximum) 1 hour (annual 0.15 4.95E- 3 1 Yes mean) 03 Ni 1 hour (annual 0.02 4.95E- 25 1 Yes mean) 03 V 1 hour 5 1.03E-01 2 10 No (maximum) 1 hour (annual 1 4.95E- 0 1 No mean) 03 Dioxins & 1 hour (annual - 9.90E-10 - - No Furans mean) PAHs 1 hour (annual 0.00025 9.90E- 4 1 Yes mean) 06 PCB 1 hour (annual 0.2 4.95E- 0 1 No mean) 05 NH3 1 hour (annual 5 4.95E- 1 1 No mean) 02

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Table 5.17 Predicted Maximum Process Contributions at Long-Term Emission Limit Values – K3

The results presented in Table 5.16 show that the predicted PC is below 10% of the relevant EAL for all pollutants except SO2 and NO2.

-3 When the 15-minute mean SO2 PC of 37.7 μg.m is added to the AC of 22.1 µg.m-3, the PEC is 59.8 µg.m-3. As this is below the relevant EAL of 266 µg.m-3 the effects are not considered to be significant.

th -3 When the 24-hour mean (99.18 percentile) SO2 PC of 15.2 μg.m is added to the AC of 8.0 µg.m-3, the PEC is 23.2 µg.m-3. As this is below the relevant EAL of 125 µg.m-3 the effects are not considered to be significant.

th -3 When the 1-hour mean (99.79 percentile) NO2 PC of 21.9 μg.m is added to the AC of 63.5 µg.m-3, the PEC is 85.4 µg.m-3. As this is below the relevant EAL of 200 µg.m-3 the effects are not considered to be significant.

The results presented in Table 5.17 show that the predicted PC is below 10% of the relevant short-term EAL and below 1% of the long-term EAL for all pollutants with the exception of nitrogen dioxide (NO2), As (arsenic), Co (cobalt), Pb (lead), Mn (manganese) Ni (nickel), and PAHs.

Table 5.18 summarises the K3 Proposed Development PECs for all pollutants that were considered to be potentially significant in Table 5.17.

Pollutant Averaging Period EAL AC (µg.m- Max K3 PEC Max Is K3 PEC (μg.m-3) 3) (μg.m-3) K3 Potentially PEC Significant? as % of EAL NO2 1 hour (annual mean) 40 31.7 33.1 83 No As 1 hour (annual mean) 0.003 7.78E-04 5.73E-03 191 Yes Co 1 hour (annual mean) 0.2 6.17E-05 5.01E-03 3 No Pb 1 hour (annual mean) 0.25 6.13E-03 1.11E-02 4 No Mn 1 hour (annual mean) 0.15 3.27E-03 8.22E-03 5 No Ni 1 hour (annual mean) 0.02 6.75E-04 5.63E-03 28 No PAHs 1 hour (annual mean) 0.00025 9.59E-05 1.06E-04 42 No Table 5.18 Predicted Environmental Concentrations at Long-Term Emission Limit Values – K3

The results presented in Table 5.18 show that the predicted PEC is below 100% of the relevant EAL for all pollutants with the exception of As (arsenic).

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Pollutant Averaging EAL Max K3 Max K3 Max K3 Max K3 Is K3 PEC Period (μg.m-3) PC PC as % PEC PEC as Potentially (µg.m-3) of EAL (μg.m-3) % of EAL Significant? As 1 hour 0.003 5.50E-04 18 1.33E-03 44 No (annual mean) Table 5.19 Predicted Environmental Concentrations at Long-Term Emission Limit Values – K3

For hexavalent chromium (CrVI), the measured concentrations in the EA ‘Releases from waste incinerators – Guidance on assessing group 3 metal stack emissions from incinerators’ version 4 (undated), varies from 0.0005% to 0.03% of the IED emission concentration limit. Table 5.20 shows the predicted PC at these proportions.

Pollutant Averaging EAL K3 PC (µg.m-3) K3 PC as % of Percentage of Period (μg.m-3) EAL the IED Emission Limit CrVI 1 hour (annual 0.0002 2. 0 0.0005% (min) mean) 1.49E-06 1 0.03% (max) Table 5.20 Predicted Environmental Concentrations at Long-Term Emission Limit Values – K3

The combined PCs for K3 and WKN Proposed Developments are considered in Section 5.12.

Traffic-related Emissions

Modelling has been undertaken for the key traffic-related pollutants (NO2, PM10 and PM2.5) at sensitive receptor locations adjacent to roads affected.

Tables 5.21, 5.22 and 5.23 present the annual-mean NO2, PM10 and PM2.5 concentrations predicted at the facades of the receptors outlined in Table 5.14 for the K3 Proposed Development in the first fully operational year, 2021. The With Development scenarios is the Without Development scenario plus stack and traffic emissions from the K3 Proposed Development. The methodology and significance criteria for the traffic modelling are provided in Appendix 5.5.

It should be noted that the NO2 future baseline concentration for the assessment of traffic emissions is based on the Defra mapped NO2 background concentration of 12.5 µg.m-3 (see Table 5.11) plus the K3 Proposed Development stack emissions rather than the baseline of 31.7 μg.m-3 used for the stack emissions. The Defra mapped concentration is a background concentration (i.e. away from roads) whereas the 31.7 µg.m-3 was measured at a roadside location and will include a large road contribution. Therefore, to avoid double counting of the road component, the Defra mapped background concentration has been used for all traffic modelling.

Receptor ID Concentration (µg.m-3) With - Impact Without Dev Descriptor as % of the Without K3 Stack With AQS Development emissions Development Objective

R1 16.6 0.56 17.2 1 Negligible R2 18.5 0.58 19.3 2 Negligible R3 16.2 0.48 16.7 1 Negligible

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Receptor ID Concentration (µg.m-3) With - Impact Without Dev Descriptor as % of the Without K3 Stack With AQS Development emissions Development Objective

R4 13.8 0.32 14.1 1 Negligible R5 13.7 0.32 14.0 1 Negligible R6 15.2 0.14 15.3 0 Negligible R7 15.6 0.13 15.8 0 Negligible R8 26.9 0.29 27.3 1 Negligible R9 26.9 0.18 27.3 1 Negligible R10 21.8 0.11 22.0 1 Negligible R11 14.0 0.12 14.1 0 Negligible R12 13.4 0.12 13.5 0 Negligible R13 13.2 0.08 13.3 0 Negligible R14 13.7 0.10 13.7 0 Negligible R15 23.2 0.06 23.2 0 Negligible R16 26.4 0.05 26.5 0 Negligible R17 22.2 0.06 22.3 0 Negligible R18 13.3 0.04 13.3 0 Negligible R19 24.8 0.35 25.5 2 Negligible R20 21.1 0.58 22.0 2 Negligible Maximum 26.9 0.58 27.3 Minimum 13.2 0.04 13.3

Table 5.21 Predicted Annual-Mean NO2 Impacts at Receptors – K3 Proposed Development

Receptor ID Concentration (µg.m-3) With - Impact Without Dev Descriptor as % of the Without K3 Stack With AQS Development emissions Development Objective

R1 16.3 0.12 16.4 0 Negligible R2 16.8 0.14 17.1 1 Negligible R3 16.1 0.12 16.3 0 Negligible R4 15.6 0.07 15.7 0 Negligible R5 15.6 0.07 15.6 0 Negligible R6 15.9 0.04 15.9 0 Negligible R7 16.0 0.04 16.0 0 Negligible R8 18.4 0.08 18.5 0 Negligible R9 18.4 0.05 18.5 0 Negligible R10 17.3 0.03 17.4 0 Negligible R11 15.6 0.03 15.7 0 Negligible R12 15.5 0.03 15.5 0 Negligible R13 15.5 0.02 15.5 0 Negligible R14 15.5 0.03 15.6 0 Negligible R15 16.5 0.02 16.5 0 Negligible R16 16.8 0.01 16.8 0 Negligible R17 16.5 0.02 16.5 0 Negligible R18 15.5 0.01 15.5 0 Negligible R19 18.2 0.09 18.4 0 Negligible R20 17.5 0.15 17.7 1 Negligible Maximum 18.4 0.15 18.5 Minimum 15.5 0.01 15.5

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Table 5.22 Predicted Annual-Mean PM10 Impacts at Receptors – K3 Proposed Development

Receptor ID Concentration (µg.m-3) With - Impact Descriptor Without Dev as % of the Without K3 Stack With AQS Development emissions Development Objective

R1 11.1 0.12 11.3 v Negligible R2 11.5 0.14 11.7 0 Negligible R3 11.1 0.12 11.2 0 Negligible R4 10.8 0.07 10.8 0 Negligible R5 10.8 0.07 10.8 0 Negligible R6 10.9 0.04 11.0 0 Negligible R7 11.0 0.04 11.0 0 Negligible R8 12.4 0.08 12.5 0 Negligible R9 12.4 0.05 12.5 0 Negligible R10 11.7 0.03 11.8 0 Negligible R11 10.8 0.03 10.8 0 Negligible R12 10.7 0.03 10.8 0 Negligible R13 10.7 0.02 10.7 0 Negligible R14 10.7 0.03 10.8 0 Negligible R15 11.4 0.02 11.4 0 Negligible R16 11.6 0.01 11.6 0 Negligible R17 11.3 0.02 11.4 0 Negligible R18 10.7 0.01 10.7 0 Negligible R19 12.2 0.09 12.4 0 Negligible R20 11.8 0.15 12.0 0 Negligible Maximum 12.4 0.15 12.5 Minimum 10.7 0.01 10.7

Table 5.23 Predicted Annual-Mean PM2.5 Impacts at Receptors – K3 Proposed Development

Predicted annual-mean NO2, PM10 and PM2.5 concentrations of the K3 Proposed Development once operational at the façades of the existing receptors are below the relevant AQS objectives. When the magnitude of change is considered in the context of the absolute concentrations, the impact descriptors are ‘negligible’ at all receptors.

-3 As all predicted annual-mean NO2 concentrations are below 60 µg.m , the hourly-mean objective for NO2 is likely to be met at all receptors. The short-term NO2 impact can be considered ‘negligible’ and is not considered further within this assessment.

-3 As all predicted annual mean PM10 concentrations are below 31.5 µg.m , the daily-mean PM10 objective is expected to be met at all receptors and the short- term PM10 impact is not considered further within this assessment.

Overall, the impact on the surrounding area from NO2, PM10 and PM2.5 is considered to be ‘negligible’, using the criteria adopted for this assessment and based on professional judgement.

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Dust Emissions

The operation of the K3 Proposed Development could potentially be associated with dust. Some of the key activities likely to generate dust during the operation of the K3 Proposed Development are:

• Delivery of waste; and

• Sorting and handling of waste.

Post recycled waste will be brought to the K3 Site in HGVs or RCVs. At arrival at the site the vehicles will be weighed on weighbridges at the site entrance before vehicles proceed to the tipping hall. Once at the tipping hall vehicles will be directed to one of the unloading bays from which waste will then be deposited into the fuel (waste) bunker. The bunker principally takes the form of a recessed rectangular pit below the floor level of the plant. The waste material can vary widely in moisture content and thermal value, so it is continually managed in the bunker to ensure consistency prior to the combustion process.

The process would produce residues in the form of bottom ash and boiler ash, together with air pollution control residue which would be collected and removed from the site for further treatment off-site.

There are dedicated areas for the reception and storage of imported material, which together with the processing and materials separation are all contained within a controlled environment.

The accepted best practice approach for the primary control of dust releases is containment within the building, which is the technique employed to be employed for the K3 Proposed Development. Air from within the waste reception hall and waste processing hall would be drawn for use as combustion air and the dust levels inside would be managed so as to comply with health and safety obligations for personal exposure. Based on the above, the magnitude of the source of emissions is considered to be small.

The wind roses illustrated in Figure 5.1 show that the prevailing wind direction is south westerly. The nearest high sensitivity receptors are residential properties on Swale Way (to the south west of the site). These properties are upwind of the site and, at 770 metres, remote from potential sources of emissions. On that basis, the risk of dust impacts from the process is considered to be very low. No significant effects are anticipated.

Odour Emissions

Source Odour Potential

The first step in the qualitative assessment of odour impact is to estimate the odour source potential which has been determined based on the guidance set out in Appendix 5.6.

Waste delivered to the K3 Site would be unloaded within the tipping hall. Therefore, the potential for odours to be released to the outside air during the delivery stage and storage stages would be minimal.

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Defra published a “Review of Environmental and Health Effects of Waste Management” (Defra, 2004). This publication included a literature review, which noted that odour is potentially significant from the waste storage and processing phases of incineration, but that odours are normally controlled via the combustion air. Combustion air for the plant would be drawn from within the buildings creating a slight negative pressure ensuring that airflow and, therefore, odours are likely to be directed into rather than out of the building. The height of the stack and the destruction of odours during the incineration process are sufficient to ensure that it is unlikely that odours from the stack would be detectable at ground level. On that basis, the Source Odour Potential has been categorised as ‘small’.

Pathway Effectiveness

The odour flux from the odour sources is dependent on the effectiveness of odour transport to the receptors, versus the mitigating effect of dilution/dispersion in the atmosphere.

The wind roses illustrated in Figure 5.1 show that the prevailing wind direction is south westerly.

Risk of Odour Exposure (Impact)

When the small Source Odour Potential (ignoring mitigation) is considered in the context of the pathway effectiveness (Appendix 5.6, Table 5.6.3), the risk of odour exposure (impact) is negligible at all receptors.

Likely Magnitude of Odour Effect

When the above risk of odour exposure impact is considered in the context of the sensitivity of the receptors using the matrix in Appendix 5.6, Table 5.6.4, the likely resulting odour effect is summarised in Table 5.24.

Receptor Source Pathway Risk Odour Receptor Likely Odour Effectiveness Exposure Sensitivity Odour Effect Potential Station Road (770m to the Negligible Negligible Small Ineffective High south west- Risk Effect upwind) Table 5.24 Likely Odour Effects at the Proposed Development Site

The likely resulting odour effect would be “negligible”. Overall, the effect is considered to be “negligible” and would not be significant.

Bioaerosol Emissions

Bioaerosols are microscopic airborne particles or droplets of biological origin. These biological aerosols are complex in nature, and may include: viruses, bacteria, actinomycetes, fungal spores, enzymes, endotoxins, mycotoxins and glucans, dust mites, protozoa, fragments of plant material, and human and animal debris (skin cells, hair, etc) that have been shed.

The individual particles vary in size from fractions of a micron to up to 30 µm or more, but many have a tendency to form larger clumps or agglomerations, or to

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attach to inert dust particles. Once airborne, bioaerosols may be transported by the wind away from the source and towards sensitive receptors.

The main effects of significant exposure of people to aerosols are on respiratory health. The main pathway is by inhalation of particles which reach the respiratory system (being of small size, most bioaerosols are inhalable and some are respirable). Other potential health effects can include irritation of the eyes and nose, nausea, headache and fatigue.

The 2009 EA Review of Methods to Measure Bioaerosols at Composting Sites [Ref 5.17] notes that the absence of definitive health-based data on dose-response relationships between bioaerosols and respiratory allergy or infection prevents the identification of an exposure level that poses no risk.

The EA takes a precautionary approach to permitting sites that emit bioaerosols, as described by its Position Statement [Ref 5.18] on permit applications for composting operations. It requires new composting operations within 250 metres of workplaces or dwellings to carry out a Site Specific Bioaerosol Risk Assessment (SSBRA) in support of their application to demonstrate that the level of bioaerosols emission attributable to the composting facility (i.e. the PC) can, and will, be maintained no higher than acceptable levels at nearby sensitive receptors. Whilst the Position Statement relates to composting facilities, it provides a useful starting point from which to assess the risks associated with bioaerosol emissions from other waste facilities. The Position Statement notes that “Generally, the complexity of a risk assessment is related to the size and complexity of the proposed facility and the uncertainty of the risk posed, varying from a qualitative, largely generic approach at one extreme to a site specific quantitative risk assessment at the other.”

The 2008 EA Science Report Development of Amenity Risk Assessments at Organic Waste Treatment Facilities [Ref 5.19] was produced to provide scientific evidence to support the development of impact assessments and included a detailed review of bioaerosol monitoring and modelling. The project drew attention to the many challenges to modelling bioaerosols and concluded that although progress had been made in dispersion modelling of bioaerosols, it could not recommend the use of models as tools in regulatory risk assessment at that time.

The difficulties of producing quantitative assessments are reflected in the Position Statement, which notes, “Standard methods of determining bioaerosol levels are available. However, based on our present scientific understanding of bioaerosols, the way they behave and their health impacts we now consider that there is currently no suitable methodology for carrying out adequate quantitative SSBRAs for new composting facilities. Accordingly, we believe that we need to take a precautionary approach and not normally permit those facilities where we would have expected a quantitative SSBRA until such time as a suitable methodology becomes available.” It clarifies that “The types of new facilities affected by this are those that would have handled more than 500 tonnes of waste at any one time and would have carried out any “composting operations in the open that are likely to result in the uncontrolled release of high levels of bioaerosols”, as defined above. In practice, this would not include situations where the entire composting operation is carried out inside a building, or where composting takes place outside, but using negative aeration and without turning. However, it would include

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compost maturation in conventional outdoor turned windrows, carried out following other treatment operations such as in-vessel composting, treatment in a dry AD (anaerobic digestion) plant and treatment in an MBT (mechanical biological treatment) plant.”

It follows that a qualitative approach may be used to assess bioaerosol impacts for facilities likely to pose a lower risk than large composting operations performed outdoors. This is consistent with the 2008 Defra-commissioned report [Ref 5.20] into the exposure-response relationships for bioaerosol emissions from waste treatment processes, which stated, “There have been relatively few studies of bioaerosol exposure at waste transfer stations, materials recovery facilities (MRFs), landfills or other waste processes” and acknowledged the difficulties in modelling and measuring bioaerosol emissions, stating that it is “… extremely difficult to define, model and measure emissions in a quantitative fashion for most waste management processes … Even where a waste process does incorporate discrete point sources that would be amenable to measurement, these sources may be small in comparison to fugitive sources elsewhere on site and be of limited relevance to overall emissions of bioaerosols from the site.”

Paragraphs 5.6.18 to 5.6.21 set out the measures to control dust. These measures will also reduce emissions of bioaerosols and, on that basis, the magnitude of the source of emissions is considered to be small.

The wind roses illustrated in Figure 5.1 show that the prevailing wind direction is south westerly. The nearest sensitive receptors are workers at Kemsley Paper Mill which is upwind of the K3 Site and, at 200 metres, remote from potential sources of bioaerosol emissions. On that basis, the risk of bioaerosol impacts from the process is considered to be low and no significant effects are anticipated.

Decommissioning Effects

The construction dust assessment undertaken as part of the original planning application for the now permitted K3 facility provided a list of recommended mitigation measures to ensure that the effect from construction would be not significant. Assuming that these mitigation measures are implemented during the decommissioning phase, the effect is expected to be not significant.

The air quality assessment for the permitted K3 did not quantitatively assess the effects of construction traffic on air quality as construction traffic flows were expected to be lower than operational traffic flows. During the decommissioning phase the traffic generated is likely to be the same or lower than during the construction phase and on that basis the effect is expected to be not significant.

Effect Receptor Impact Nature Duration Degree of Identified Sensitivity Magnitude Effect Construction Effects Increase High, medium Low Adverse Short-term Negligible in and low deposited and suspended dust

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Effect Receptor Impact Nature Duration Degree of Identified Sensitivity Magnitude Effect Completed Development Effects Increase High Low Adverse Long-term Negligible in air quality pollutants (stack and traffic- related emissions) Decommissioning Effects Increase High, medium Low Adverse Short-term Negligible in and low deposited and suspended dust Table 5.25 – Summary of Effects Prior to Mitigation

5.7 The Practical Effect of the K3 Proposed Development

Planning permission for K3, an energy-from-waste facility with a generating capacity of 49.9MW and an annual tonnage throughput of 550,000 tonnes of waste, was granted by Kent County Council on the 6th March 2012. A number of material and non-material amendments have been made to that original consent since then.

Construction of K3 began in 2016, with the facility expected to be fully operational to its consented generating capacity (49.9MW) and tonnage throughput (550,000 tonnes) by late 2019. The practical effect of the K3 Proposed Development allow K3 as consented and currently being built to operate to an upgraded power generation level of 75MW (an additional 25.1MW) and to process 657,000 tonnes of waste per annum (an additional 107,000 tonnes) above and beyond that permitted under its existing planning permission. For further details refer to Chapter 2.

Construction Effects

The practical effect of the consent sought would not result in any additional external physical changes to K3 as permitted and the layout and appearance of the facility will remain as per its consented design. There would be no additional construction work.

Completed Development Effects

The increase in power output and tonnage throughput increase to K3 as consented will increase the concentration of emissions from the facility. For each of the five years of meteorological data (2012 to 2016), the maximum predicted concentration across the identified selected sensitive receptors has been derived and are reported below. The predicted Process Contribution (PC) is the K3 Proposed Development PC – the K3 Permitted Development PC. i.e. it is contribution associated with the increased waste throughput.

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Scenario 1: Short-Term IED Emission Limit Values

Table 5.26 summarises the maximum predicted PC to ground-level concentrations for all relevant pollutants with short-term emission limit values set out in the IED.

Scenario 2: Long-Term IED Emission Limit Values

Table 5.27 summarises the PCs for all pollutants assuming that the K3 Proposed Development is operating at long-term emission limit values.

Max Max Is Increase Increas Increas EAL in K3 PC Pollutan e in K3 e in K3 Criteri Averaging Period (μg.m Potentially t PC PC as a (%) -3) Significant (μg.m- % of ? 3) EAL HCl 1 hour (maximum) 750 1.4 0 10 No HF 1 hour (maximum) 160 0.1 0 10 No 15 minute (99.90th 266 4.2 2 10 No percentile) SO2 1 hour (99.73th percentile) 350 2.9 1 10 No 24 hour (99.18th percentile) 125 1.5 1 10 No

NO2 1 hour (99.79th percentile) 200 2.2 1 10 No

PM10 24 hour (90.41st percentile) 50 0.1 0 10 No 8 hour (maximum daily 1000 CO 1.4 0 10 No running) 0 Table 5.26 Predicted Maximum Process Contributions at Short-Term Emission Limit Values – Increase in K3

Pollutant Averaging Period EAL Max Max Criteri Is Increase (μg.m-3) Increase Increase a (%) in K3 PC in K3 in K3 Potentiall PC PC as % y (μg.m-3) of EAL Significant ? PM10 24 hour (90.41st 50 0.03 0 10 No percentile) 24 hour (annual mean) 40 0.01 0 1 No

PM2.5 24 hour (annual mean) 25 0.01 0 1 No HCl 1 hour (maximum) 750 0.24 0 10 No HF 1 hour (maximum) 160 0.02 0 10 No

SO2 15 minute (99.90th 266 1.04 0 10 No percentile) 1 hour (99.73th 350 0.74 0 10 No percentile) 24 hour (99.18th 125 0.37 0 10 No percentile) 1 hour (annual mean) 50 0.03 0 1 No

NO2 1 hour (99.79th 200 1.10 1 10 No percentile) 1 hour (annual mean) 40 0.09 0 1 No CO 8 hour (maximum 10,000 0.72 0 10 No daily running) Cd 1 hour (annual mean) 0.005 3.62E- 1 10 No 05 Tl 1 hour (maximum) 30 1.21E-03 0 10 No

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Pollutant Averaging Period EAL Max Max Criteri Is Increase (μg.m-3) Increase Increase a (%) in K3 PC in K3 in K3 Potentiall PC PC as % y (μg.m-3) of EAL Significant ? 1 hour (annual mean) 1 3.62E- 0 1 No 05 Hg 1 hour (maximum) 7.5 1.21E-03 0 10 No 1 hour (annual mean) 0.25 3.62E- 0 1 No 05 Sb 1 hour (maximum) 150 1.21E-02 0 10 No 1 hour (annual mean) 5 3.62E- 0 1 No 04 As 1 hour (annual mean) 0.003 3.62E- 12 1 Yes 04 Cr 1 hour (maximum) 150 1.21E-02 0 10 No 1 hour (annual mean) 5 3.62E- 0 1 No 04 Co 1 hour (maximum) 6 1.21E-02 0 10 No 1 hour (annual mean) 0.2 3.62E- 0 1 No 04 Cu 1 hour (maximum) 200 1.21E-02 0 10 No 1 hour (annual mean) 10 3.62E- 0 1 No 04 Pb 1 hour (annual mean) 0.25 3.62E- 0 1 No 04 Mn 1 hour (maximum) 1500 1.21E-02 0 10 No 1 hour (annual mean) 0.15 3.62E- 0 1 No 04 Ni 1 hour (annual mean) 0.02 3.62E- 2 1 Yes 04 V 1 hour (maximum) 5 1.21E-02 0 10 No 1 hour (annual mean) 1 3.62E- 0 1 No 04 Dioxins & 1 hour (annual mean) - 6.59E-11 No Furans PAHs 1 hour (annual mean) 0.00025 6.59E- 0 1 No 07 PCB 1 hour (annual mean) 0.2 3.30E- 0 1 No 06 NH3 1 hour (annual mean) 5 3.30E- 0 1 No 03 Table 5.27 Predicted Maximum Process Contributions at Long-Term Emission Limit Values – Increase in K3

The results presented in Table 5.26 show that the predicted PC is below 10% of the relevant EAL for all pollutants and the impacts at short-term emission limits are therefore not considered significant.

The results presented in Table 5.27 show that the predicted PC is below 10% of the relevant short-term EAL and below 1% of the long-term EAL for all pollutants with the exception of As (arsenic) and Ni (nickel).

The predictions are based on the assumption that arsenic and nickel each comprise the total of the group 3 metals IED emission limit. In reality, the IED emission limit applies to all nine of the group 3 metals. If the emission limit is therefore assumed to apply equally for each of the nine group 3 metals, then the PC for As and Ni would be divided by 9 (and therefore makes up 11% of the IED emission limit

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value) and the predicted PC for As would be less than 1% of the EAL. This is likely to be a conservative assumption: The EA ‘Releases from waste incinerators – Guidance on assessing group 3 metal stack emissions from incinerators’ version 4 (undated), outlines monitoring data from 18 Municipal Waste Incinerators and Waste Wood Co-Incinerators between 2007 and 2015. For arsenic measured concentrations were between 0.04 to 5.0% of the group 3 metals IED emission limit value. For nickel the measured concentrations ranged from 0.5 to 44.0 % of the group 3 metals IED emission limit value. The guidance notes “that the two highest nickel concentrations are outliers being 44%, as above, and 27% of the ELV. The third highest concentration is 0.53 mg/Nm3 or 11% of the ELV”. If nickel was assumed to make up 44% of the emission limit value, the PC would be 1% of the EAL. On that basis, the impacts of As and Ni are not considered significant.

Pollu Averaging Period EAL Max Increase Max Increase Percentage of the tant (μg.m-3) in K3 PC in K3 PC as IED Emission Limit (µg.m-3) % of EAL CrVI 1 hour (annual 0.0002 1.81E-09 0 0.0005% (min) mean) 1.09E-07 0 0.03% (max) Table 5.28 Predicted Environmental Concentrations at Long-Term Emission Limit Values – increase in K3

The combined PCs for K3 and WKN Proposed Developments are considered in Section 5.12.

Traffic-related Emissions

The results of an assessment of the impacts associated with vehicles generated by the K3 Proposed Development is provided in Section 5.6.

The practical effect of the K3 Proposed Development would be an additional 68 HGV movements per day on the A259, Barge Way and part of the Swale Way above that associated with K3 as consented. The indicative criterion of 100 vehicles outside an AQMA is therefore not exceeded.

The traffic flows are expected to be significantly lower on other routes as the traffic redistributes. Therefore, the aforementioned EPUK & IAQM traffic-flow thresholds are not expected to be exceeded for any individual road and the impacts of exhaust emissions associated with the K3 Proposed Development, compared with the permitted K3, have not been assessed specifically and can be considered to be negligible.

The practical effect of the K3 Proposed Development will not increase staff numbers beyond those associated with K3 as consented.

Decommissioning Effects

The construction dust assessment undertaken as part of the original planning application for the now permitted K3 facility provided a list of recommended

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mitigation measures to ensure that the effect from construction would be not significant. A Decommissioning Environmental Management Plan will be produced and assuming that these mitigation measures are implemented during the decommissioning phase, the effect is expected to be not significant.

Effect Receptor Impact Nature Duration Degree of Identified Sensitivity Magnitude Effect Construction Effects N/A - - - - - Completed Development Effects Increase High Low Adverse Long-term Negligible in air quality pollutants (stack and traffic- related emissions) Decommissioning Effects Increase High, medium Low Adverse Short-term Negligible in and low deposited and suspended dust Table 5.29 – Summary of Effects Prior to Mitigation

5.8 Mitigation for the K3 Proposed Development

Mitigation from Completed Development Effects

Predicted concentrations of pollutants from the completed development have been demonstrated by the assessment to meet all relevant air quality standards and objectives. The air quality effect is considered to be “not significant”. On that basis, no further mitigation measures are considered necessary.

Mitigation from Decommissioning Effects

A detailed Decommissioning Environmental Management Plan (DEMP) is to form a requirement of the DCO, which will require the DEMP to be submitted for written approval prior to any decommissioning works. This will detail the IAQM dust guidance mitigation measures to be employed to minimise dust effects.

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5.9 Residual Effects

Residual effects are those that are predicted to remain after implementation of mitigation measures. The residual air quality effects are summarised in Table 5.30.

Residual Receptor Impact Nature Duration Degree of Effect Sensitivity Magnitude Effect Identified Increase High Low Adverse Long-term Negligible in air quality pollutants Table 5.30: Residual air quality effects

5.10 WKN Proposed Development Predicted Effects

Construction Effects

Traffic-related Emissions

Modelling has been undertaken for the key traffic-related pollutants (NO2, PM10 and PM2.5) at sensitive receptor locations adjacent to roads affected.

Tables 5.31, 5.32 and 5.33 present the annual-mean NO2, PM10 and PM2.5 concentrations predicted at the facades of the receptors outlined in Table 5.14 for the WKN Proposed Development during the construction year, 2021. The ‘Without Development’ scenario assumes that K3 as consented is operational. The methodology and significance criteria for the traffic modelling are provided in Appendix 5.5.

Receptor Concentration (µg.m-3) With - Without Impact Descriptor ID Dev as % of the AQS Without With Objective Development Development

R1 17.1 17.2 0 Negligible R2 19.2 19.4 0 Negligible R3 16.7 16.8 0 Negligible R4 14.1 14.1 0 Negligible R5 14.0 14.0 0 Negligible R6 15.3 15.3 0 Negligible R7 15.8 15.8 0 Negligible R8 27.2 27.5 1 Negligible R9 27.2 27.5 1 Negligible R10 21.9 22.1 0 Negligible R11 14.1 14.2 0 Negligible R12 13.5 13.5 0 Negligible R13 13.3 13.3 0 Negligible R14 13.7 13.7 0 Negligible R15 23.2 23.2 0 Negligible R16 26.5 26.5 0 Negligible R17 22.3 22.3 0 Negligible R18 13.3 13.3 0 Negligible R19 25.4 25.7 1 Negligible Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 5-42

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Receptor Concentration (µg.m-3) With - Without Impact Descriptor ID Dev as % of the AQS Without With Objective Development Development

R20 21.9 22.2 1 Negligible Maximum 27.2 27.5 - - Minimum 13.3 13.3 - -

Table 5.31 Predicted Annual-Mean NO2 Impacts at Receptors – WKN Proposed Development, Construction Traffic

Receptor Concentration (µg.m-3) With - Without Impact Descriptor ID Dev as % of the AQS Without With Objective Development Development

R1 16.4 16.4 0 Negligible R2 17.0 17.1 0 Negligible R3 16.3 16.3 0 Negligible R4 15.7 15.7 0 Negligible R5 15.6 15.6 0 Negligible R6 15.9 15.9 0 Negligible R7 16.0 16.0 0 Negligible R8 18.5 18.6 0 Negligible R9 18.5 18.6 0 Negligible R10 17.4 17.4 0 Negligible R11 15.7 15.7 0 Negligible R12 15.5 15.5 0 Negligible R13 15.5 15.5 0 Negligible R14 15.6 15.6 0 Negligible R15 16.5 16.5 0 Negligible R16 16.8 16.8 0 Negligible R17 16.5 16.5 0 Negligible R18 15.5 15.5 0 Negligible R19 18.4 18.4 0 Negligible R20 17.7 17.8 0 Negligible Maximum 18.5 18.6 0 - Minimum 15.5 15.5 0 -

Table 5.32 Predicted Annual-Mean PM10 Impacts at Receptors – WKN Proposed Development, Construction Traffic

Receptor Concentration (µg.m-3) With - Without Impact Descriptor ID Dev as % of the AQS Objective Without With Development Development

R1 11.3 11.3 0 Negligible R2 11.6 11.7 0 Negligible R3 11.2 11.2 0 Negligible R4 10.8 10.8 0 Negligible R5 10.8 10.8 0 Negligible R6 11.0 11.0 0 Negligible R7 11.0 11.0 0 Negligible R8 12.5 12.5 0 Negligible R9 12.4 12.5 0 Negligible R10 11.8 11.8 0 Negligible R11 10.8 10.8 0 Negligible Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 5-43

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Receptor Concentration (µg.m-3) With - Without Impact Descriptor ID Dev as % of the AQS Objective Without With Development Development

R12 10.8 10.8 0 Negligible R13 10.7 10.7 0 Negligible R14 10.8 10.8 0 Negligible R15 11.4 11.4 0 Negligible R16 11.6 11.6 0 Negligible R17 11.4 11.4 0 Negligible R18 10.7 10.7 0 Negligible R19 12.4 12.4 0 Negligible R20 12.0 12.1 0 Negligible Maximum 12.5 12.5 0 - Minimum 10.7 10.7 0 -

Table 5.33 Predicted Annual-Mean PM2.5 Impacts at Receptors – WKN Proposed Development, Construction Traffic

Predicted annual-mean NO2, PM10 and PM2.5 concentrations of the WKN Proposed Development during the construction phase at the façades of the existing receptors are below the relevant AQS objectives. When the magnitude of change is considered in the context of the absolute concentrations, the impact descriptors are ‘negligible’ at all receptors.

Overall, the impact on the surrounding area from NO2, PM10 and PM2.5 is considered to be ‘negligible’, using the criteria adopted for this assessment and based on professional judgement.

Construction Dust

The level and distribution of demolition and construction dust emissions will vary according to factors such as the type and size of dust, duration and location of dust-generating activity, weather conditions and the effectiveness of suppression methods.

The main effect of any dust emissions, if not mitigated, could be annoyance due to soiling of surfaces, particularly windows, cars and laundry. However, it is normally possible, by implementation of proper control, to ensure that dust deposition does not give rise to significant adverse effects, although short-term events may occur (for example, due to technical failure or exceptional weather conditions). The following assessment, using the IAQM methodology, predicts the risk of dust impacts and the level of mitigation that is required to control the residual effects to a level that is “not significant”.

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Risk of Dust Impacts

Source

The WKN Site is currently being used by the Applicant as a laydown and parking area for the construction of the adjacent K3 and so no demolition will occur.

The WKN Site area is more than 10,000 m2, the dust emission magnitude for the earthworks phase is classified as large.

The total volume of the buildings to be constructed would be between 25,000 and 100,000 m3, the dust emission magnitude for the construction phase is classified as medium.

The maximum number of deliveries to the WKN Site in any one day is expected to be more than 50 HDVs. The dust emission magnitude for trackout would be classified as large.

The source magnitudes in each of the three phases are summarised in Table 5.34.

Earthworks Construction Trackout Large Medium Large Table 5.34: Dust Emission Magnitude for Earthworks, Construction and Trackout

Pathway and Receptor

All earthworks and construction activities are assumed to occur within the DCO boundary. As such, receptors at distances within 20 m, 50 m, 100 m, 200 m and 350 m of the site boundary have been identified. The sensitivity of the area has been classified and the results are provided in Table 5.35 below.

Potential Impact Sensitivity of the Reason for Sensitivity Classification Surrounding Area There are few highly sensitive receptors in the area. The closest residential properties Dust Soiling Low are more than 350 m from the Site (Appendix 5.1, Table A4)

Background PM10 concentrations for the Human Health Low assessment is below 24 µg.m-3 (Appendix 5.1, Table A5) Table 5.35: Sensitivity of the Surrounding Area for Demolition, Earthworks and Construction

The Dust Emission Magnitude for trackout is classified as medium and trackout may occur on roads up to 500 m from the site. The sensitivity of the area has been classified and the results are provided in Table 5.36 below.

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Potential Impact Sensitivity of the Reason for Sensitivity Classification Surrounding Area The nearest highly sensitive receptors are the residential properties to the west of Swale Dust Soiling Low Way. These are more than 500 m from the Site (Appendix 5.1, Table A4)

Background PM10 concentrations for the Human Health Low assessment is below 24 µg.m-3 (Appendix 5.1, Table A5) Table 5.36: Sensitivity of the Surrounding Area for Trackout

Overall Dust Risk

The Dust Emission Magnitude has been considered in the context of the Sensitivity of the Area (Appendix 5.1, Tables A6 to A9) to give the Dust Impact Risk. Table 5.37 summarises the Dust Impact Risk for earthworks, construction and trackout without the implementation of mitigation.

Source Earthworks Construction Trackout Dust Soiling Low Low Low Human Health Low Low Low Risk Low Low Low Table 5.37 Dust Impact Risk for Earthworks, Construction and Trackout – Without Mitigation

Taking the site as a whole, the overall risk is deemed to be low. The mitigation measures appropriate to a level of risk for the site as a whole and for each of the three phases of activity.

Provided this package of mitigation measures is implemented, the residual construction dust effects will not be significant. The IAQM dust guidance states that “For almost all construction activity, the aim should be to prevent significant effects on receptors through the use of effective mitigation. Experience shows that this is normally possible. Hence the residual effect will normally be ‘not significant’.” The IAQM dust guidance recommends that significance is only assigned to the effect after the activities are considered with mitigation in place. The agreed mitigation measures would be included in a CEMP, to be secured via a requirement in the DCO.

Completed Development Effects

Stack Emissions

For each of the five years of meteorological data (2012 to 2016), the maximum predicted concentration across the identified selected sensitive receptors has been derived and are reported below.

Scenario 1: Short-Term IED Emission Limit Values

Table 5.38 summarises the maximum predicted WKN Proposed Development PC to ground-level concentrations for all relevant pollutants with short-term emission limit values set out in the IED.

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Scenario 2: Long-Term IED Emission Limit Values

Table 5.39 summarises the WKN Proposed Development PCs for all pollutants assuming that the proposed development is operating at long-term emission limit values.

Pollutant Averaging Period EAL Max Max Criteria Is WKN PC (μg.m- WKN WKN (%) Potentially 3) PC PC Significant? (μg.m- as % 3) of EAL HCl 1 hour (maximum) 750 10.1 1 10 No HF 1 hour (maximum) 160 0.7 0 10 No

SO2 15 minute (99.90th percentile) 266 25.8 10 10 Yes 1 hour (99.73th percentile) 350 21.4 6 10 No 24 hour (99.18th percentile) 125 10.2 8 10 No

NO2 1 hour (99.79th percentile) 200 15.8 8 10 No

PM10 24 hour (90.41st percentile) 50 0.6 1 10 No CO 8 hour (maximum daily running) 10000 10.3 0 10 No Table 5.38 Predicted Maximum Process Contributions at Short-Term Emission Limit Values - WKN

Pollutant Averaging Period EAL Max Max Criteria Is WKN PC (μg.m-3) WKN PC WKN (%) Potentially (μg.m-3) PC Significant? as % of EAL PM10 24 hour (90.41st percentile) 50 0.21 0 10 No 24 hour (annual mean) 40 0.06 0 1 No

PM2.5 24 hour (annual mean) 25 0.06 0 1 No HCl 1 hour (maximum) 750 1.69 0 10 No HF 1 hour (maximum) 160 0.17 0 10 No

SO2 15 minute (99.90th percentile) 266 6.44 2 10 No 1 hour (99.73th percentile) 350 5.35 2 10 No 24 hour (99.18th percentile) 125 2.55 2 10 No 1 hour (annual mean) 50 0.33 1 1 No

NO2 1 hour (99.79th percentile) 200 7.88 4 10 No 1 hour (annual mean) 40 0.92 2 1 Yes CO 8 hour (maximum daily running) 10,000 5.16 0 10 No Cd 1 hour (annual mean) 0.005 3.30E-04 7 10 No Tl 1 hour (maximum) 30 8.47E-03 0 10 No 1 hour (annual mean) 1 3.30E-04 0 1 No Hg 1 hour (maximum) 7.5 8.47E-03 0 10 No 1 hour (annual mean) 0.25 3.30E-04 0 1 No Sb 1 hour (maximum) 150 8.47E-02 0 10 No 1 hour (annual mean) 5 3.30E-03 0 1 No As 1 hour (annual mean) 0.003 3.30E-03 110 1 Yes Cr 1 hour (maximum) 150 8.47E-02 0 10 No 1 hour (annual mean) 5 3.30E-03 0 1 No Co 1 hour (maximum) 6 8.47E-02 1 10 No 1 hour (annual mean) 0.2 3.30E-03 2 1 Yes Cu 1 hour (maximum) 200 8.47E-02 0 10 No

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Pollutant Averaging Period EAL Max Max Criteria Is WKN PC (μg.m-3) WKN PC WKN (%) Potentially (μg.m-3) PC Significant? as % of EAL 1 hour (annual mean) 10 3.30E-03 0 1 No Pb 1 hour (annual mean) 0.25 3.30E-03 1 1 No Mn 1 hour (maximum) 1500 8.47E-02 0 10 No 1 hour (annual mean) 0.15 3.30E-03 2 1 Yes Ni 1 hour (annual mean) 0.02 3.30E-03 16 1 Yes V 1 hour (maximum) 5 8.47E-02 2 10 No 1 hour (annual mean) 1 3.30E-03 0 1 No Dioxins & 1 hour (annual mean) - 6.58E-10 - - No Furans PAHs 1 hour (annual mean) 0.00025 6.58E-06 3 1 Yes PCB 1 hour (annual mean) 0.2 3.30E-05 0 1 No

NH3 1 hour (annual mean) 5 3.30E-02 1 1 No Table 5.39 Predicted Maximum Process Contributions at Long-Term Emission Limit Values - WKN

The results presented in Table 5.38 show that the predicted PC is below 10% of the relevant EAL for all pollutants except SO2 and the impacts at short-term emission limits are therefore not considered significant. When the 15-minute -3 -3 mean SO2 is added to the future AC of 56.5 µg.m , the PEC is 82.3µg.m . As this is below the relevant EAL of 266 µg.m-3 the effects are not considered to be significant.

The results presented in Table 5.39 show that the predicted PC is below 10% of the relevant short-term EAL and below 1% of the long-term EAL for all pollutants with the exception of annual-mean NO2, As (arsenic), Co (cobalt), Mn (manganese), Ni (nickel) and PAHs.

Table 5.40 summarises the WKN Proposed Development PECs for all pollutants that were considered to be potentially significant in Table 5.39.

Pollutant Averaging Period EAL Future Max WKN Max Is WKN PEC (μg.m-3) AC PEC WKN Potentially (µg.m- (μg.m-3) PEC Significant? 3) as % of EAL NO2 1 hour (annual mean) 40 33.1 34.0 85 No As 1 hour (annual mean) 0.003 5.53E- 8.83E-03 294 Yes 03 Co 1 hour (annual mean) 0.2 4.82E- 8.12E-03 4 No 03 Mn 1 hour (annual mean) 0.15 8.02E- 1.13E-02 8 No 03 Ni 1 hour (annual mean) 0.02 5.43E- 8.73E-03 44 No 03 PAHs 1 hour (annual mean) 0.00025 1.06E- 1.12E-04 45 No 04 Table 5.40 Predicted Environmental Concentrations at Long-Term Emission Limit Values - WKN

The results presented in Table 5.40 show that the predicted PEC is below 100% of the relevant EAL for all pollutants with the exception of As (arsenic).

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The predictions are based on the assumption that arsenic comprises the total of the group 3 metals emissions. In reality, the IED emission limit applies to all nine of the group 3 metals. If the emissions limit is assumed to apply equally to each of the nine group 3 metals, then the PCs (and the WKN Proposed Development) for As for the would be divided by 9 (or 11%) and the predicted PEC for As would be less than 100% of the EAL as shown in Table 5.41 and the effects are therefore not considered significant. As discussed in paragraph 5.7.9, measured concentrations of arsenic ranged from 0.04 to 5.0% of the group 3 emission limit value so this is a conservative assumption.

Is WKN Max Max Max Future Max PEC Averagi WKN WKN WKN Pollut EAL AC WKN Potenti ng PC PC as PEC as ant (μg.m-3) (µg.m- PEC ally Period (µg.m- % of % of 3) (μg.m-3) Signific 3) EAL EAL ant? 1 hour 3.67E- 1.31E- 1.67E- As (annual 0.003 12 56 No 04 03 03 mean) Table 5.41 Predicted Environmental Concentrations at Long-Term Emission Limit Values - WKN

Pollutant Averaging EAL Max WKN Max WKN Percentage Period (μg.m-3) PC (µg.m-3) PC as % of of the IED EAL Emission Limit CrVI 1 hour 0.0002 1.65E-08 0 0.0005% (annual (min) mean) 9.90E-07 0 0.03% (max) Table 5.42 Predicted Environmental Concentrations at Long-Term Emission Limit Values – WKN

The PC at each end of the range is below 1% of the EAL and the impacts are not considered significant.

The combined PCs for the K3 and WKN Proposed Developments are considered in Section 5.12.

Traffic-related Emissions

Modelling has been undertaken for the key traffic-related pollutants (NO2, PM10 and PM2.5) at sensitive receptor locations adjacent to roads affected.

Tables 5.43, 5.44 and 5.45 present the annual-mean NO2, PM10 and PM2.5 concentrations predicted at the facades of the receptors outlined in Table 5.14 for the WKN Proposed Development in the opening year, 2024. The ‘Without development’ scenario assumes that the permitted K3 is operational. The PCs from stack emissions of the WKN Proposed Development at each of these receptors have been added to the With Development scenario and an Impact Descriptor has been derived based on EPUK&IAQM guidance. The methodology and significance criteria for the traffic modelling are provided in Appendix 5.5.

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It should be noted that the NO2 future baseline concentration is based on the -3 Defra mapped NO2 background concentration of 12.5 µg.m (see Table 5.11) plus the PC from K3. For the stack emissions, a baseline of 31.7 µg.m-3 representing the maximum AC across the grid was used. The Defra mapped concentration is a background concentration whereas the 31.7 µg.m-3 was measured at a roadside location. Therefore, to avoid double counting of the road component, the Defra mapped background concentration has been used for all traffic modelling.

Receptor Concentration (µg.m-3) With - Impact Descriptor ID Without Dev as % Without WKN With of the Development Stack Development AQS Emissions Objective R1 16.0 0.36 16.4 1 Negligible R2 17.4 0.64 18.1 2 Negligible R3 15.6 0.53 16.2 1 Negligible R4 13.8 0.28 14.1 1 Negligible R5 13.6 0.25 13.9 1 Negligible R6 14.6 0.16 14.8 0 Negligible R7 14.9 0.16 15.1 0 Negligible R8 23.4 0.27 23.7 1 Negligible R9 23.3 0.18 23.6 1 Negligible R10 19.4 0.11 19.5 0 Negligible R11 13.7 0.12 13.8 0 Negligible R12 13.3 0.11 13.4 0 Negligible R13 13.1 0.08 13.2 0 Negligible R14 13.4 0.10 13.5 0 Negligible R15 20.6 0.06 20.7 0 Negligible R16 23.2 0.05 23.2 0 Negligible R17 19.9 0.06 19.9 0 Negligible R18 13.1 0.04 13.2 0 Negligible R19 21.9 0.47 22.4 1 Negligible R20 19.3 0.53 19.9 2 Negligible Maximum 23.4 0.64 23.7 - - Minimum 13.1 0.04 13.2 - -

Table 5.43 Predicted Annual-Mean NO2 Impacts at Receptors – WKN Proposed Development

Receptor Concentration (µg.m-3) With - Impact ID Without Descriptor Dev as % of Without WKN Stack With the AQS Development Emissions Development Objective

R1 16.4 0.02 16.4 0 Negligible R2 17.0 0.04 17.1 0 Negligible R3 16.2 0.04 16.3 0 Negligible R4 15.7 0.02 15.7 0 Negligible R5 15.6 0.02 15.7 0 Negligible R6 15.9 0.01 15.9 0 Negligible R7 16.0 0.01 16.0 0 Negligible R8 18.4 0.02 18.5 0 Negligible R9 18.4 0.01 18.5 0 Negligible R10 17.3 0.01 17.3 0 Negligible R11 15.6 0.01 15.7 0 Negligible R12 15.5 0.01 15.5 0 Negligible R13 15.5 0.01 15.5 0 Negligible R14 15.6 0.01 15.6 0 Negligible R15 16.4 <0.005 16.4 0 Negligible

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Receptor Concentration (µg.m-3) With - Impact ID Without Descriptor Dev as % of Without WKN Stack With the AQS Development Emissions Development Objective

R16 16.7 <0.005 16.7 0 Negligible R17 16.4 <0.005 16.4 0 Negligible R18 15.5 <0.005 15.5 0 Negligible R19 18.3 0.03 18.4 0 Negligible R20 17.7 0.04 17.8 0 Negligible Maximum 18.4 0.04 18.5 0 - Minimum 15.5 <0.005 15.5 0 - Table 5.44 Predicted Annual-Mean PM10 Impacts at Receptors – WKN Proposed Development

Receptor Concentration (µg.m-3) With - Impact Descriptor ID Without Dev as % Without WKN With of the Development Stack Development AQS Emissions Objective R1 11.2 0.02 11.3 0 Negligible R2 11.6 0.04 11.7 0 Negligible R3 11.2 0.04 11.2 0 Negligible R4 10.8 0.02 10.9 0 Negligible R5 10.8 0.02 10.8 0 Negligible R6 10.9 0.01 10.9 0 Negligible R7 11.0 0.01 11.0 0 Negligible R8 12.4 0.02 12.4 0 Negligible R9 12.3 0.01 12.4 0 Negligible R10 11.7 0.01 11.7 0 Negligible R11 10.8 0.01 10.8 0 Negligible R12 10.7 0.01 10.8 0 Negligible R13 10.7 0.01 10.7 0 Negligible R14 10.8 0.01 10.8 0 Negligible R15 11.3 <0.005 11.3 0 Negligible R16 11.5 <0.005 11.5 0 Negligible R17 11.3 <0.005 11.3 0 Negligible R18 10.7 <0.005 10.7 0 Negligible R19 12.3 0.03 12.3 0 Negligible R20 12.0 0.04 12.0 0 Negligible Maximum 12.4 0.04 12.4 0 - Minimum 10.7 <0.005 10.7 0 - Table 5.45 Predicted Annual-Mean PM2.5 Impacts at Receptors – WKN Proposed Development

Predicted annual-mean NO2, PM10 and PM2.5 concentrations in the opening year of the WKN Proposed Development at the façades of the existing receptors are below the relevant AQS objectives. When the magnitude of change is considered in the context of the absolute concentrations, the impact descriptors are ‘negligible’ at all receptors.

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Overall, the impact on the surrounding area from NO2, PM10 and PM2.5 is considered to be ‘negligible’, using the criteria adopted for this assessment and based on professional judgement.

Dust Emissions

The operation of the WKN Proposed Development could potentially be associated with dust emissions. Sources of dust would be the same as for K3. The magnitude of the source of emissions is considered to be small.

Odour Emissions

The operation of the WKN Proposed Development could potentially be associated with odour emissions. Sources of odour would be the same as K3. The magnitude of the source of emissions is considered to be small.

Taking into account the pathway effectiveness and the sensitivity of receptors, as for K3, the likely resulting odour effect would be “negligible”. Overall, the effect is considered to be “negligible” and would not be significant.

Bioaerosol Emissions

The approach to the assessment of bio-aerosol impacts is described in paragraph 5.6.37 to 5.6.46.

With the implementation of measures to control dust, as for K3, the magnitude of the source of emissions is considered to be small.

The wind roses illustrated in Figure 5.1 show that the prevailing wind direction is south westerly. The nearest sensitive receptors are workers at Kemsley Paper Mill which is upwind of the WKN Site and, at 200 metres, remote from potential sources of bioaerosol emissions. On that basis, the risk of bioaerosol impacts from the process is considered to be low and no significant effects are anticipated.

Decommissioning Phase

The risk of impacts during decommissioning and demolition phase will be the same or similar to the risk of impacts during the construction phase. With the effective implementation of the mitigation measures recommended for the construction phase, the residual effects are unlikely to be significant. A detailed Decommissioning Environmental Management Plan (DEMP) is to form a

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requirement of the DCO, which will require the DEMP to be submitted for written approval prior to any decommissioning works. This will detail the IAQM dust guidance mitigation measures to be employed to minimise dust effects.

During the decommissioning phase the traffic generated is likely to be the same or lower than during the construction phase and on that basis the effect is expected to

Effect Receptor Impact Nature Duration Degree of Identified Sensitivity Magnitude Effect Construction Effects Increase in High, medium Low Adverse Short-term Negligible deposited and low and suspended dust Completed Development Effects Increase in High Low Adverse Long-term Negligible air pollutants including stack, vehicular emissions, dust, odour and bioaerosols Decommissioning Effects Increase in High, medium Low Adverse Short-term Negligible deposited and low and suspended dust Table 5.46 Summary of Effects Prior to Mitigation

5.11 Mitigation

Mitigation for Construction Effects

The IAQM dust guidance lists mitigation measures for low, medium and high dust risks.

As summarised in Table 5.27, the predicted Dust Impact Risk is classified as low. The measures listed below are based on the IAQM dust guidance ‘highly recommended’ measures for low risk sites. The agreed mitigation measures would be included in a CEMP, a draft of which is included as Appendix 2.1.

Preparing and maintaining the site

• Plan site layout so that machinery and dust causing activities are located away from receptors, as far as is possible.

• Avoid site runoff of water or mud.

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Operating vehicle/machinery and sustainable travel

• Ensure all vehicles switch off engines when stationary – no idling vehicles.

Operations

• Use enclosed chutes and conveyors and covered skips.

Waste management

• Avoid bonfires and burning of waste materials.

Communications

• Display the name and contact details of person(s) accountable for air quality and dust issues on the site boundary. This may be the environment manager/engineer or the site manager.

• Display the head or regional office contact information.

Site Management

• Record all dust and air quality complaints, identify cause(s), take appropriate measures to reduce emissions in a timely manner, and record the measures taken.

• Make the complaints log available to the local authority when asked.

• Record any exceptional incidents that cause dust and/or air emissions, either on- or off-site, and the action taken to resolve the situation in the log book.

• Develop and implement a Dust Management Plan.

Monitoring

• Carry out regular site inspections to monitor compliance with a Dust Management Plan, record inspection results, and make an inspection log available to the local authority when asked.

Mitigation for Completed Development Effects

Mitigation for Decommissioning Effects

The nature of the decommissioning phase would remain similar to the construction phase and subject to the same or similar mitigation measures as set out in CEMP. Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 5-54

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A Decommissioning Environmental Management Plan (DEMP) is to be produced and subject to the approval of the planning authority prior to the future decommissioning of the WKN Proposed Development As such, it can be concluded that the potential effects on air quality would remain the same as assessed for construction and would not be significant.

5.12 Residual Effects

Residual effects are those that are predicted to remain after implementation of mitigation measures described above. The residual air quality effects are summarised in Table 5.47.

Residual Receptor Impact Nature Duration Degree of Effect Sensitivity Magnitude Effect Identified Increase High Low Adverse Long-term Negligible in air quality pollutants (stack emissions, traffic- related emissions, dust, odour and bioaerosol emissions) Table 5.47 Summary of Residual Effects

5.13 Cumulative Effects

Stack Emissions

Table 5.48 and Table 5.49 summarises the cumulative PCs for the K3 and WKN Proposed Developments for five scenarios:

• The K3 Proposed Development + other cumulative developments

• The practical effect of the K3 Proposed Development + other cumulative developments

• WKN Proposed Development + other cumulative developments

• WKN Proposed Development + K3 Proposed Development + other cumulative developments.

• WKN Proposed Development + the practical effect of the K3 Proposed Development + other cumulative developments. Table 5.48 and Table 5.49 also summarise the cumulative PECs.

Figures 5.3 and 5.4 illustrate the long and short-term NO2 contours for the combined PC associated with the WKN Proposed Development and the practical

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effect of the K3 Proposed Development. The point of maximum impact is not at a location where the public are regularly present.

The sections below outline the ‘other cumulative developments’ considered.

During the construction and decommissioning phase, there is the potential for cumulative effects where there are other sources of dust located within 700 metres of the project (the IAQM indicative maximum radius of effects for an individual construction site being 350m). Large construction sites would typically implement mitigation measures, such as those recommended in the IAQM dust guidance. With the effective implementation of appropriate mitigation measures at other construction sites within 700 metres of the project, the residual cumulative dust effects are unlikely to be significant.

Once the proposed development is completed, there is the potential for cumulative effects where there are other sources of combustion-related pollutants in close proximity to the site. This section considers the cumulative effects of the proposed developments with other schemes that are operational /constructed, consented or for which planning permissions are currently being sought. The cumulative traffic effects are considered later in this chapter.

Other Cumulative Sites Considered

16/501228/FULL – 500 m northwest - Construction of a new baling plant building within an existing waste paper storage yard. The Environmental Aspects report accompanying the planning application identified the main likely sources of emissions to air as emissions from vehicle movements generated by the operation of the proposed development. The Environmental Aspects report concluded that the air quality effects were not significant. The main area of impact from the WKN Proposed Development and K3 stack is to the north-east of the stack. Therefore there is unlikely to be any overlap in the air quality impacts from the proposed development and the new baling plant.

16/507687/COUNTY – 150 m northeast - Construction and operation of an Incinerator Bottom Ash recycling facility. Wheelabrator Technologies have confirmed that they plan to withdraw this application.

SW/11/1291 – 700 m north - Construction of an anaerobic digestion (AD) plant at the Kemsley Paper Mill. Two scenarios were modelled for the assessment, with and without heat recovery, and the maximum PCs across the grid were higher for the with heat recovery scenario. The maximum PCs from Table 7.21 of the Kemsley AD application [Ref 5.21] have been added to give a cumulative PEC in Table 5.39 and 5.40.

18/500393/FULL – 1 km southeast - Erection of a natural gas fuelled reserve power plant with maximum export capacity of up to 12 MW. The maximum PCs at modelled discrete receptors from Tables 6.1, 6.3 and 6.5 of the air quality assessment [Ref 5.22] have been added to the cumulative PEC in Table 5.39 and 5.37. For CO, no maximum PC across the grid is included so the maximum PC at the modelled discrete receptors has been used instead. Construction traffic from this development has been considered in the cumulative traffic modelling.

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15/500348/COUNTY – 800 m northwest - Land Off Kemsley Fields Business Park Barge Way Sittingbourne Kent. Installation of advance thermal conversion and energy facility at Kemsley Fields Business Park to produce energy and heat, including construction of new buildings to house thermal conversion and energy generation plant and equipment; construction of associated offices; erection of external plant including storage tanks; and erection of discharge stack (KCC planning application KCC/SW/0010/2015 refers). The maximum PCs from Table 19 of the air quality assessment [Ref 5.23] has been added to the cumulative PEC in Table 5.39 and 5.40. Traffic generated by the development has been included in the traffic data modelled.

SW/14/0224 – 1.5 km southeast - Erection of solar arrays of photovoltaic panels, inverter and transformer sheds, fencing, site storage cabin, combined DNO and EPC switchgear housing, internal gravel access road, and associated equipment. There are no potential sources of emissions to air. As such, no cumulative effects are anticipated.

16/506935/COUNTY – 200 m north - Planning Application for a Steam Pipeline connecting the existing Ridham Dock Biomass Facility to the Kemsley Paper Mill at Ridham Dock. The Planning Application Supporting Statement prepared in June 2016 by SLR did not identify air quality as environmental issue. As such, no significant cumulative effects are expected.

16/506193/ENVSCR EIA Screening Opinion – 2.1 km northwest - Outline application for proposed residential development of 275 dwellings including affordable housing with open spaces, appropriate landscaping and minor alterations to the surrounding highway network (access). SBC’s Screening Opinion dated 23 August 2016 states that the environmental effects are not considered to be sufficiently significant to warrant to Environmental Impact Assessment. Based on this and the information currently available, no significant cumulative effects are expected.

15/502197/FULL – Extension to existing yard and HGV parking area including installation of 5 no. lighting columns, landscaping, drainage and amendments to existing balancing pond. There are no significant sources to air so no significant cumulative air quality effects are expected.

18/502489/FULL Construction of a 7.2m wide internal access road and pedestrian footpath, together with the associated removal of existing water holding lagoon, chemical building and works yard. Erection of a new chemical store, works yard and engine store, breaking out and crushing of existing concrete hardstanding, lighting and landscape planting. There are no significant sources to air so no significant cumulative air quality effects are expected.

15/504458/FULL Formation or new rear access road and extension to trailer park to serve Kemsley Paper Mill and ancillary development including attenuation pond, security kiosk and weightbringers. There are no significant sources to air so no significant cumulative air quality effects are expected.

SW/14/0191 Extension to existing HGV Fitters shed plus small additional storage building. There are no significant sources to air so no significant cumulative air quality effects are expected.

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17/505919/COUNTY County Matter: For extension of the existing IBA Recycling Facility by the use of an adjoining building and land; and associated amendments to the layout of the site. There are no significant sources to air so no significant cumulative air quality effects are expected.

17/502834/FULL Installation of new underground water pipeline via open cut trenching and directional auger boring, including working area and site compounds. There are no significant sources to air so no significant cumulative air quality effects are expected.

16/507943/FULL Construction of an agricultural anaerobic digestion plant and associated infrastructure, for the purposes of generating renewable energy. A full air quality assessment has not been undertaken. On the basis that a full assessment was not required and that the site is over 5 km from the Proposed Development, no significant cumulative air quality effects are expected.

17/503032/FULL Installation of an electricity battery storage facility within a new steel framed portal building and ancillary infrastructure. There are no significant sources to air so no significant cumulative air quality effects are expected.

18/503075/NSIP Consultation - Construction and Operation of Photovoltaic (PV) Electricity Generating and Storage. There are no significant sources to air so no significant cumulative air quality effects are expected.

15/506005/COUNTY EIA Screening opinion (County) to determine whether an environmental impact assessment is required for the proposed establishment of a secondary aggregate recycling facility and the reworking of existing aggregate deposits at Rushenden Marshes Disposal Site. No further detail about the site is available, but as it is over 4.5km from the Proposed Development no significant cumulative air quality effects are expected.

15/506166/ENVSCR EIA Screening Opinion - Redevelopment of site, comprising demolition of selected buildings, extension, refurbishment and remodelling of selected buildings and the erection of new buildings to provide up to 88,000sqm, comprising laboratories, offices incubation/innovation hubs; 400sqm of retail and up to 300-400 dwellings. No further detail about the site is available, but as it is nearly 6 km from the Proposed Development no significant cumulative air quality effects are expected.

17/504034/COUNTY County Matter - Provision of a new car park, drainage layout and SUDs pond to accommodate and support the existing waste management facility. The additional staff movements have already been included in extant permission so not included in the cumulative traffic.

17/502678/COUNTY Section 73 application to vary conditions 15 and 16 of planning permission SW/12/1184 to permit the facility to operate during a wider range of hours and to also change the number of vehicle movements associated with the operations. The additional traffic movements are minimal so have not been included in cumulative traffic data.

18/503873/ENVSCR EIA Screening Opinion Application for housing and country park. At this stage only a scoping report has been submitted. As there is a lack of information available this development is not considered further.

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SW/13/1571 The erection of four wind turbines with a maximum blade tip height of up to 126.5 metres, together with a substation and control building, associated hardstandings, an improved access junction, connecting internal access tracks, and other related infrastructure. Traffic generated by this development would be temporary and has therefore not been included in the cumulative traffic data.

SW/13/1495 Variation of condition 9 of planning permission SW/11/548 (use of building 15B to install and operate materials recycling facility (MRF) and a refuse derived fuel (RDF) facility and to use existing weighbridge, weighbridge office, site office and washroom/toilets to the south of building 15a) to allow an increase of HGV movements from 58 to 98 (49 in and 49 out) for a temporary period of 12 months Traffic generated by this development would be temporary and has therefore not been included in the cumulative traffic data.

14/501181/COUNTY KCC Regulation 13. Scoping opinion as to the scope of an environmental impact assessment for a proposed combined heat and power plant at Ridham B. At this stage only a scoping report has been submitted. As there is a lack of information available this development is not considered further.

MC/18/2229 request for a screening opinion as to whether an Environmental Impact Assessment is necessary for the development of a new cement plant.

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Max PC Max PC + total of other developments Max Max (μg.m-3) (μg.m-3) PEC PEC + (μg.m- as % 3) of EAL Polluta Averaging EAL Kemsley Kemsl Reserv Garden K3 Practic WKN WKN + WKN + K3 Proposed nt Period (μg.m-3) K4 CHP ey AD e of Propos al K3 the Development + PC (SW/11 Power Englan ed effect Propose practic WKN + AC + (EN0100 /1291) Plant d Develo of the d al other 90 PC Energy pment K3 Develop effect developments (18/501 (18/50 Facilit Propos ment of the 923/ADJ 0393/F y ed K3 )) ULL) (15/50 Develo Propos 0348/ pment ed COUN Develo TY) pment HCl 1 hour 750 - - - 13.6 25.9 15.0 23.7 36.0 25.1 37.2 5 (maximum) HF 1 hour 160 - - - 0.9 1.7 1.0 1.6 2.4 1.7 4.9 3 (maximum) SO2 15 minute 266 - - - 33.4 71.0 37.5 59.1 96.8 63.3 118.9 45 (99.90th percentile) 1 hour 350 - - - 29.9 60.0 32.9 51.3 81.4 54.3 97.1 28 (99.73th percentile) 24 hour 125 - - - 13.5 28.7 15.0 23.7 38.9 25.2 46.9 37 (99.18th percentile) NO2 1 hour 200 12.79 18.10 19.57 21.40 93.8 74.1 87.6 109.6 89.8 173.0 87 (99.79th percentile) PM10 24 hour 50 - - - 1.1 2.1 1.2 1.8 2.7 1.8 22.1 44 (90.41st percentile) CO 8 hour 10000 131 116 13.9 275.9 263.1 272.0 286.2 273.4 828.2 8 (maximum daily running) Table 5.48 Cumulative Predicted Environmental Concentrations at Short-Term Emission Limit Values

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Max PC Max PC + total of other developments Max Max (μg.m-3) (μg.m-3) PEC PEC + (μg.m- as % 3) of EAL Polluta Averaging EAL Kemsley Kemsl Reserv Garden K3 Practic WKN WKN + WKN + K3 Proposed nt Period (μg.m-3) K4 CHP ey AD e of Propos al K3 the Development + PC (SW/11 Power Englan ed effect Propose practic WKN + AC + (EN0100 /1291) Plant d Develo of the d al other 90 PC Energy pment K3 Develop effect developments (18/501 (18/50 Facilit Propos ment of the 923/ADJ 0393/F y ed K3 )) ULL) (15/50 Develo Propos 0348/ pment ed COUN Develo TY) pment PM10 24 hour 50 - - - 0.38 0.7 0.4 0.6 0.9 0.6 20.3 41 (90.41st percentile) 24 hour 40 - - - 0.12 0.2 0.1 0.2 0.3 0.2 19.7 49 (annual mean) PM2.5 24 hour 25 - - - 0.12 0.2 0.1 0.2 0.3 0.2 10.7 43 (annual mean) HCl 1 hour 750 - - - 2.26 4.3 2.5 3.9 6.0 4.2 7.2 1 (maximum) HF 1 hour 160 - - - 0.23 0.4 0.2 0.4 0.6 0.4 3.1 2 (maximum) SO2 15 minute 266 - - - 8.34 17.8 9.4 14.8 24.2 15.8 46.3 17 (99.90th percentile) 1 hour 350 - - - 7.48 15.0 8.2 12.8 20.4 13.6 36.0 10 (99.73th percentile) 24 hour 125 - - - 3.37 7.2 3.7 5.9 9.7 6.3 17.7 14 (99.18th percentile) 1 hour 50 - - - - 0.5 <0.05 0.3 0.8 0.4 2.9 6 (annual mean)

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Max PC Max PC + total of other developments Max Max (μg.m-3) (μg.m-3) PEC PEC + (μg.m- as % 3) of EAL Polluta Averaging EAL Kemsley Kemsl Reserv Garden K3 Practic WKN WKN + WKN + K3 Proposed nt Period (μg.m-3) K4 CHP ey AD e of Propos al K3 the Development + PC (SW/11 Power Englan ed effect Propose practic WKN + AC + (EN0100 /1291) Plant d Develo of the d al other 90 PC Energy pment K3 Develop effect developments (18/501 (18/50 Facilit Propos ment of the 923/ADJ 0393/F y ed K3 )) ULL) (15/50 Develo Propos 0348/ pment ed COUN Develo TY) pment NO2 1 hour 200 12.79 18.10 19.57 10.70 72.1 62.3 69.0 80.0 70.1 143.5 72 (99.79th percentile) 1 hour 40 0.7 1.3 0.9 1.62 5.9 4.6 5.5 6.9 5.6 38.6 97 (annual mean) CO 8 hour 10,000 - - - 6.97 14.1 7.7 12.1 19.2 12.8 561.2 6 (maximum daily running) Cd 1 hour 0.005 - - - 5.800 1.08E- 6.16E- 9.10E- 1.41E- 9.46E- 1.53E- 31 (annual E-04 03 04 04 03 04 03 mean) Tl 1 hour 30 - - - 1.100E 2.13E- 1.22E- 1.95E- 2.98E- 2.07E- 2.98E- 0 (maximum) -02 02 02 02 02 02 02 1 hour 1 - - - 5.800 1.08E- 6.16E- 9.10E- 1.41E- 9.46E- 1.41E- 0 (annual E-04 03 04 04 03 04 03 mean) Hg 1 hour 7.5 - - - 1.100E 2.13E- 1.22E- 1.95E- 2.98E- 2.07E- 3.05E- 0 (maximum) -02 02 02 02 02 02 02 1 hour 0.25 - - - 5.800 1.08E- 6.16E- 9.10E- 1.41E- 9.46E- 2.19E- 1 (annual E-04 03 04 04 03 04 03 mean) Sb 1 hour 150 - - - 1.130E 2.16E- 1.25E- 1.98E- 3.01E- 2.10E- 3.01E- 0 (maximum) -01 01 01 01 01 01 01

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Max PC Max PC + total of other developments Max Max (μg.m-3) (μg.m-3) PEC PEC + (μg.m- as % 3) of EAL Polluta Averaging EAL Kemsley Kemsl Reserv Garden K3 Practic WKN WKN + WKN + K3 Proposed nt Period (μg.m-3) K4 CHP ey AD e of Propos al K3 the Development + PC (SW/11 Power Englan ed effect Propose practic WKN + AC + (EN0100 /1291) Plant d Develo of the d al other 90 PC Energy pment K3 Develop effect developments (18/501 (18/50 Facilit Propos ment of the 923/ADJ 0393/F y ed K3 )) ULL) (15/50 Develo Propos 0348/ pment ed COUN Develo TY) pment 1 hour 5 - - - 5.800 1.08E- 6.16E- 9.10E- 1.41E- 9.46E- 1.41E- 0 (annual E-03 02 03 03 02 03 02 mean) As 1 hour 0.003 - - - 0.000 5.59E- 1.00E- 3.94E- 8.89E- 4.30E- 9.67E- 322 (annual 638 03 03 03 03 03 03 mean) Cr 1 hour 150 - - - 1.130E 2.16E- 1.25E- 1.98E- 3.01E- 2.10E- 3.01E- 0 (maximum) -01 01 01 01 01 01 01 1 hour 5 - - - 5.800 1.08E- 6.16E- 9.10E- 1.41E- 9.46E- 1.54E- 0 (annual E-03 02 03 03 02 03 02 mean) Co 1 hour 6 - - - 1.130E 2.16E- 1.25E- 1.98E- 3.01E- 2.10E- 3.01E- 5 (maximum) -01 01 01 01 01 01 01 1 hour 0.2 - - - 5.800 1.08E- 6.16E- 9.10E- 1.41E- 9.46E- 1.41E- 7 (annual E-03 02 03 03 02 03 02 mean) Cu 1 hour 200 - - - 1.130E 2.16E- 1.25E- 1.98E- 3.01E- 2.10E- 3.05E- 0 (maximum) -01 01 01 01 01 01 01 1 hour 10 - - - 5.800 1.08E- 6.16E- 9.10E- 1.41E- 9.46E- 1.86E- 0 (annual E-03 02 03 03 02 03 02 mean) Pb 1 hour 0.25 - - - 5.800 1.08E- 6.16E- 9.10E- 1.41E- 9.46E- 2.02E- 8 (annual E-03 02 03 03 02 03 02 mean) Mn 1 hour 1500 - - - 1.130E 2.16E- 1.25E- 1.98E- 3.01E- 2.10E- 3.04E- 0 (maximum) -01 01 01 01 01 01 01

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Max PC Max PC + total of other developments Max Max (μg.m-3) (μg.m-3) PEC PEC + (μg.m- as % 3) of EAL Polluta Averaging EAL Kemsley Kemsl Reserv Garden K3 Practic WKN WKN + WKN + K3 Proposed nt Period (μg.m-3) K4 CHP ey AD e of Propos al K3 the Development + PC (SW/11 Power Englan ed effect Propose practic WKN + AC + (EN0100 /1291) Plant d Develo of the d al other 90 PC Energy pment K3 Develop effect developments (18/501 (18/50 Facilit Propos ment of the 923/ADJ 0393/F y ed K3 )) ULL) (15/50 Develo Propos 0348/ pment ed COUN Develo TY) pment 1 hour 0.15 - - - 5.800 1.08E- 6.16E- 9.10E- 1.41E- 9.46E- 1.73E- 12 (annual E-03 02 03 03 02 03 02 mean) Ni 1 hour 0.02 - - - 5.800 1.08E- 6.16E- 9.10E- 1.41E- 9.46E- 1.47E- 74 (annual E-03 02 03 03 02 03 02 mean) V 1 hour 5 - - - 6.000 1.09E- 1.81E- 9.07E 1.94E- 1.03E- 1.94E- 4 (maximum) E-03 01 02 -02 01 01 01 1 hour 1 - - - 5.800 1.08E- 6.16E- 9.10E- 1.41E- 9.46E- 1.47E- 1 (annual E-03 02 03 03 02 03 02 mean) Dioxins 1 hour - - - - 1.200E 2.19E- 1.27E- 1.86E- 2.85E- 1.92E- 1.32E- - & (annual -09 09 09 09 09 09 08 Furans mean) PAHs 1 hour 0.00025 - - - 1.200E 1.11E- 1.86E- 7.78E- 1.77E- 8.44E- 1.14E- 45 (annual -06 05 06 06 05 06 04 mean) PCB 1 hour 0.2 - - - 1.200E 4.96E- 3.42E- 3.31E- 8.26E- 3.64E- 1.83E- 0 (annual -07 05 06 05 05 05 04 mean) NH3 1 hour 5 - - - 1.160E 1.66E- 1.19E- 1.49E- 1.99E- 1.52E- 1.19E+ 24 (annual -01 01 01 01 01 01 00 mean) Table 5.49 Cumulative Predicted Environmental Concentrations at Long-Term Emission Limit Values

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The values presented in Table 5.48 and 5.49 are the predictions at the location of maximum impact. In reality, the maximum impacts for each stack are unlikely to occur at the same location. Therefore, the results in these tables can be considered highly conservative.

The results presented in Table 5.48 show that the cumulative PECs are below the EAL for all pollutants and the effects are therefore not considered significant.

The results presented in Table 5.49 show that the cumulative PECs are below the relevant EALs for all pollutants except As (arsenic).

For As (arsenic) the predictions are based on the assumption that arsenic comprises the total of the group 3 metals emissions. In reality, the IED emission limit applies to all nine of the group 3 metals. If the predicted PC is assumed to apply equally to each of the nine group 3 metals, i.e. the PC for As is divided by 9, the predicted cumulative PEC for As would be less than 100% of the EAL as shown in Table 5.50 and the effects are therefore not considered significant.

Pollutant Averag EAL K3 Proposed Development K3 Proposed Development ing (μg.m-3) + WKN + other + WKN + other Period developments developments + AC (μg.m-3) (μg.m-3)

Max PC Max PC as Max PEC Max PEC as (μg.m-3) % of EAL (μg.m-3) % of EAL

As 1 hour 0.003 9.88E-04 32.9 1.77E-03 59 (annual mean) Table 5.50 Cumulative Predicted Environmental Concentrations at Long-Term Emission Limit Values

Traffic-related Emissions

An assessment of cumulative traffic-related emissions has been undertaken for the following scenarios:

• With and Without the WKN Proposed Development construction traffic and K3 Proposed Development in the opening year of the K3 Proposed Development, 2021.

• With and Without the WKN and K3 Proposed Development traffic in the opening year of WKN, 2024.

Both of these scenarios are based on traffic data that considers a number of other cumulative developments.

The practical effect of the K3 Proposed Development would be an additional 68 HGV movements per day on the A259, Barge Way and part of the Swale Way above that associated with K3 as consented. The indicative EPUK/IAQM criterion of 100 vehicles outside an AQMA is therefore not exceeded and the impacts are not considered to be significant.

Chapter 4: Traffic and Transport discusses in detail the cumulative traffic data and the cumulative developments included in each scenario are summarised below.

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The traffic data includes the following committed developments:

• SW/18/503317 Amendment K3 to allow for additional Refuse Collection Vehicles

• Removal of vehicles associated with the IBA facility adjacent to the Wheelabrator Kemsley Generating Station (KCC/SW/0265/2016).

• 16/501484/COUNTY – 1 km north - Construction of a gypsum recycling building on land at Ridham Dock.

• 14/500327/OUT – 250 m south - Development of Fulcrum Business Park and extension to Milton Creek Country Park.

• 15/510589/OUT – 2.2 km south- Development of a business park (Eurolink V) on land north of Northern Relief Road.

• 15/500348/COUNTY – 800 m northwest - Land Off Kemsley Fields Business Park Barge Way Sittingbourne Kent. Installation of advance thermal conversion and energy facility at Kemsley Fields Business Park to produce energy and heat, including construction of new buildings to house thermal conversion and energy generation plant and equipment; construction of associated offices; erection of external plant including storage tanks; and erection of discharge stack (KCC planning application KCC/SW/0010/2015 refers).

• 17/505073/FULL- 800 m south - Erection of a tile factory including service yard, storage yard and car parking area.

• 14/501588/OUT Outline application for the development of 550-600 houses and all necessary supporting infrastructure including roads, open space, play areas, neighbourhood shopping/community facilities (up to 650 sq m gross) and landscaping. All detailed matters are reserved for subsequent approval except (i) vehicular access to A2 Fox Hill; (ii) emergency access to Peel Drive; (iii) landscape buffer between housing and countryside gap and (iv) layout, planting, biodiversity enhancement and management of countryside gap, as amended by drawings 5257/OPA/SK001 Rev J (new red line plan), D119/52 (Swanstree Avenue Plan) and D119/53 (junction layout plan). At this stage only the scoping report has been submitted and so the lack of information means it is not possible to include this development.

• 16/507877/FULL Erection of a residential development comprising 383 dwellings including associated access, parking, public open spaces and landscaping. New vehicular/pedestrian access from Eurolink Way and further secondary vehicular/pedestrian access off Crown Quay Lane. Associated drainage and earthworks.

• 16/507594/COUNTY County Matter - phased extraction of brickearth, advance planting, access improvements, restoration and replanting back to agricultural use.

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• 18/500257/EIFUL – 2.4 km southwest - Proposed development of 155 dwellings.

• 18/502190/EIHYB Full Planning Application - Phase 1 North - Erection of 91 dwellings accessed from Grovehurst Road, public open and amenity space (including an equipped children's play area) together with associated landscaping and ecological enhancement works, acoustic barrier to the A249, internal access roads, footpaths, cycleways and parking, drainage (including infiltration basins and tanked permeable paving), utilities and service infrastructure works. Full Planning Application - Phase 1 South - Erection of 252 dwellings (including 34 affordable dwellings) accessed from Quinton Road, public open and amenity space, together with associated landscaping and ecological enhancement works, internal access roads, footpaths, cycleways and parking, drainage (including infiltration swales, ring soakaways, and permeable paving), utilities and service infrastructure works. Outline Planning Application - for up to 857 new dwellings (including 10% affordable housing, subject to viability), a site of approximately 10 ha for a secondary and primary school, a mixed use local centre, including land for provision of a convenience store, public open and amenity space (including equipped children's play areas), together with associated landscaping and ecological enhancement works, acoustic barrier to the A249, internal access roads, footpaths, cycleways and parking, drainage (including a foul water pumping station and sustainable drainage systems), utilities and service infrastructure. All matters reserved, except for access for the schools site from Grovehurst Road.

The 2021 cumulative traffic data includes two additional developments:

• EN010090 (18/501923/ADJ)) Kemsley K4 CHP - Construction traffic

• 18/500393/FULL Natural gas fuelled reserve power plant - Construction traffic

The 2024 cumulative traffic data includes four additional developments included in the Swale Borough Council Bearing Fruit 2031 Local Plan 2017 Allocations:

• A17 Iwade Expansion – Construction traffic

• MU1 North West Sittingbourne - minimum of 1,500 dwellings, community facilities and structural landscaping and open space adjacent the A249. – part operational/part construction traffic

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The following Swale Borough Council Bearing Fruit 2031 Local Plan 2017 Allocations were not included in the 2021 or 2024 cumulative traffic data either because of the geographical location or the likely timing of the development. More detail is provided in Chapter 4: Traffic and Transport:

• A1 Land allocated for 'B' class employment uses

• A10 Housing allocations for a mix of at least 240 dwellings

• A3 Planning permission will be granted for employment uses (use classes B1, B2 or B8)

• A4 Planning permission will be granted for employment uses on sites north and south of the A249 at Cowstead Corner, as shown on the Proposals Map. The northern site is allocated for a hotel (use class C1), whilst the southern site for use classes B1, B2 or B8.

• MU4 Planning permission will be granted for mixed uses comprising approximately 260 dwellings, 26,840 sqm of 'B' use class employment, open space and landscaping

• MU5 Planning permission will be granted for mixed-uses, comprising 1,500 sqm of commercial floorspace, together with some 330 homes and proposals for the conservation, enhancement, and long term management of the site's ecological and heritage assets

The effects of these additional cumulative developments have not been specifically assessed as the traffic generated would increase the future baseline concentration only; the difference between the ‘with development’ and ‘without development’ scenarios would remain the same. If the change is small (i.e. less than 1% of the AQS Objective) the impact descriptors would be ‘negligible’ at all receptors regardless of the absolute concentration.

Results of Cumulative Traffic Modelling - WKN Proposed Development construction traffic and K3 Proposed Development in the opening year of the K3 Proposed Development, 2021.

Earlier traffic modelling in this chapter, provides the predicted impacts with WKN operating with the K3 Permitted Development.

Tables 5.51, 5.52 and 5.53 present the annual-mean NO2, PM10 and PM2.5 concentrations predicted at the facades of the receptors outlined in Table 5.14 for the WKN Proposed Development Construction traffic and K3 Proposed Development in the opening year of the K3 Proposed Development, 2021. The difference between the Without development and With development scenarios in this case is the following:

• WKN Proposed Development construction traffic emissions

• K3 Proposed Development operational traffic emission

• K3 Proposed Development stack emissions

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• Other cumulative developments traffic emissions

The Impact Descriptor has been derived based on EPUK&IAQM guidance. The methodology and significance criteria for the traffic modelling are provided in Appendix 5.5.

Receptor Concentration (µg.m-3) With - Impact Descriptor ID Without Dev as % Without K3 Stack With of the AQS Development Emissions Development Objective

R1 16.6 0.56 17.3 2 Negligible R2 18.5 0.58 19.6 3 Negligible R3 16.2 0.48 16.8 2 Negligible R4 13.8 0.32 14.2 1 Negligible R5 13.7 0.32 14.0 1 Negligible R6 15.2 0.14 15.4 0 Negligible R7 15.6 0.13 15.8 1 Negligible R8 26.9 0.29 27.7 2 Negligible R9 26.9 0.18 27.7 2 Negligible R10 21.8 0.11 22.2 1 Negligible R11 14.0 0.12 14.2 0 Negligible R12 13.4 0.12 13.6 0 Negligible R13 13.2 0.08 13.3 0 Negligible R14 13.7 0.10 13.8 0 Negligible R15 23.2 0.06 23.3 0 Negligible R16 26.4 0.05 26.5 0 Negligible R17 22.2 0.06 22.4 0 Negligible R18 13.3 0.04 13.3 0 Negligible R19 24.8 0.35 26.0 3 Negligible R20 21.1 0.58 22.4 3 Negligible Maximum 26.9 0.58 27.7 - - Minimum 13.2 0.04 13.3 - - Table 5.51 Predicted Annual-Mean NO2 Impacts at Receptors – WKN Proposed Development Construction Traffic and K3 Proposed Development

Receptor Concentration (µg.m-3) With - Impact Descriptor ID Without Dev as % Without K3 Stack With of the AQS Development Emissions Development Objective

R1 16.3 0.12 16.4 0 Negligible R2 16.8 0.14 17.1 1 Negligible R3 16.1 0.12 16.3 0 Negligible R4 15.6 0.07 15.7 0 Negligible R5 15.6 0.07 15.7 0 Negligible R6 15.9 0.04 15.9 0 Negligible R7 16.0 0.04 16.0 0 Negligible R8 18.4 0.08 18.6 1 Negligible R9 18.4 0.05 18.6 1 Negligible R10 17.3 0.03 17.4 0 Negligible R11 15.6 0.03 15.7 0 Negligible R12 15.5 0.03 15.6 0 Negligible R13 15.5 0.02 15.5 0 Negligible R14 15.5 0.03 15.6 0 Negligible R15 16.5 0.02 16.5 0 Negligible R16 16.8 0.01 16.8 0 Negligible

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Receptor Concentration (µg.m-3) With - Impact Descriptor ID Without Dev as % Without K3 Stack With of the AQS Development Emissions Development Objective

R17 16.5 0.02 16.5 0 Negligible R18 15.5 0.01 15.5 0 Negligible R19 18.2 0.09 18.5 1 Negligible R20 17.5 0.15 17.9 1 Negligible Maximum 18.4 0.14 18.6 - - Minimum 15.5 0.01 15.5 - - Table 5.52 Predicted Annual-Mean PM10 Impacts at Receptors – WKN Proposed Development Construction Traffic and K3 Proposed Development

Receptor Concentration (µg.m-3) With - Impact ID Without Descriptor Dev as % of Without K3 Stack With the AQS Development Emissions Development Objective

R1 11.1 0.12 11.3 0 Negligible R2 11.5 0.14 11.7 1 Negligible R3 11.1 0.12 11.2 0 Negligible R4 10.8 0.07 10.9 0 Negligible R5 10.8 0.07 10.8 0 Negligible R6 10.9 0.04 11.0 0 Negligible R7 11.0 0.04 11.0 0 Negligible R8 12.4 0.08 12.5 0 Negligible R9 12.4 0.05 12.5 0 Negligible R10 11.7 0.03 11.8 0 Negligible R11 10.8 0.03 10.8 0 Negligible R12 10.7 0.03 10.8 0 Negligible R13 10.7 0.02 10.7 0 Negligible R14 10.7 0.03 10.8 0 Negligible R15 11.4 0.02 11.4 0 Negligible R16 11.6 0.01 11.6 0 Negligible R17 11.3 0.02 11.4 0 Negligible R18 10.7 0.01 10.7 0 Negligible R19 12.2 0.09 12.5 0 Negligible R20 11.8 0.15 12.1 1 Negligible Maximum 12.4 0.15 12.5 - - Minimum 10.7 0.01 10.7 - - Table 5.53 Predicted Annual-Mean PM2.5 Impacts at Receptors – WKN Proposed Development Construction Traffic and K3 Proposed Development

Predicted annual-mean NO2, PM10 and PM2.5 concentrations in the opening year of the K3 Proposed Development at the façades of the existing receptors are below the relevant AQS objectives. When the magnitude of change is considered in the context of the absolute concentrations, the impact descriptors are ‘negligible’ at all receptors.

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Overall, the impact on the surrounding area from NO2, PM10 and PM2.5 is considered to be ‘negligible’, using the criteria adopted for this assessment and based on professional judgement.

Results of Cumulative Traffic Modelling - WKN and K3 Proposed Development traffic in the opening year of WKN, 2024.

Tables 5.54, 5.55 and 5.56 present the annual-mean NO2, PM10 and PM2.5 concentrations predicted at the facades of the receptors outlined in Table 5.14 for the WKN and K3 Proposed Development in the opening year of WKN, 2024. The difference between the Without development and With development scenarios are the following:

• WKN Proposed Development operational traffic emissions

• WKN stack emissions

• K3 Proposed Development operational traffic emissions

• K3 Proposed Development stack emissions

• Other cumulative developments traffic emissions

An Impact Descriptor has been derived based on EPUK&IAQM guidance. The methodology and significance criteria for the traffic modelling are provided in Appendix 5.5.

Receptor Concentration (µg.m-3) With - Impact ID Without Descriptor Dev as % Without K3 Stack WKN With of the Development Emissions Stack Development AQS Emissions Objective R1 15.5 0.56 0.36 16.5 2 Negligible R2 16.7 0.58 0.64 18.2 4 Negligible R3 15.2 0.48 0.53 16.3 3 Negligible R4 13.5 0.32 0.28 14.1 2 Negligible R5 13.4 0.32 0.25 13.9 1 Negligible R6 14.5 0.14 0.16 14.8 1 Negligible R7 14.8 0.13 0.16 15.1 1 Negligible R8 23.1 0.29 0.27 24.1 3 Negligible R9 23.1 0.18 0.18 24.0 2 Negligible R10 19.3 0.11 0.11 19.8 1 Negligible R11 13.6 0.12 0.12 13.9 1 Negligible R12 13.2 0.12 0.11 13.4 1 Negligible R13 13.0 0.08 0.08 13.2 0 Negligible R14 13.4 0.10 0.10 13.6 1 Negligible R15 20.6 0.06 0.06 20.7 0 Negligible R16 23.1 0.05 0.05 23.2 0 Negligible R17 19.8 0.06 0.06 20.0 1 Negligible R18 13.1 0.04 0.04 13.2 0 Negligible

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Receptor Concentration (µg.m-3) With - Impact ID Without Descriptor Dev as % Without K3 Stack WKN With of the Development Emissions Stack Development AQS Emissions Objective R19 21.4 0.35 0.47 22.7 3 Negligible R20 18.6 0.58 0.53 20.1 4 Negligible Maximum 23.1 0.58 0.64 24.1 - - Minimum 13.0 0.04 0.04 13.2 - - Table 5.54 Predicted Annual-Mean NO2 Impacts at Receptors – WKN and K3 Proposed Development

Receptor Concentration (µg.m-3) With - Impact ID Without Descriptor Dev as % Without K3 Stack WKN Stack With of the Development Emissions Emissions Development AQS Objective R1 16.2 0.12 0.02 16.4 0 Negligible R2 16.8 0.14 0.04 17.1 1 Negligible R3 16.1 0.12 0.04 16.3 1 Negligible R4 15.6 0.07 0.02 15.7 0 Negligible R5 15.6 0.07 0.02 15.7 0 Negligible R6 15.8 0.04 0.01 15.9 0 Negligible R7 16.0 0.04 0.01 16.0 0 Negligible R8 18.3 0.08 0.02 18.6 1 Negligible R9 18.3 0.05 0.01 18.6 1 Negligible R10 17.2 0.03 0.01 17.4 0 Negligible R11 15.6 0.03 0.01 15.7 0 Negligible R12 15.5 0.03 0.01 15.6 0 Negligible R13 15.5 0.02 0.01 15.5 0 Negligible R14 15.5 0.03 0.01 15.6 0 Negligible R15 16.4 0.02 <0.005 16.5 0 Negligible R16 16.7 0.01 <0.005 16.8 0 Negligible R17 16.4 0.02 <0.005 16.5 0 Negligible R18 15.5 0.01 <0.005 15.5 0 Negligible R19 18.1 0.09 0.03 18.4 1 Negligible R20 17.4 0.15 0.04 17.8 1 Negligible Maximum 18.3 0.15 0.04 18.6 - - Minimum 15.5 0.01 <0.005 15.5 - - Table 5.55 Predicted Annual-Mean PM10 Impacts at Receptors – WKN and K3 Proposed Development

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Overall, the impact on the surrounding area from NO2, PM10 and PM2.5 is considered to be ‘negligible’, using the criteria adopted for this assessment and based on professional judgement.

Summary of Cumulative Effects

K3 Proposed Development + other cumulative developments

As shown in Table 5.48 – 5.50 and discussed in paragraphs 5.13.33 to 5.13.36, the cumulative effects across the grid for the K3 Proposed Development + other cumulative developments are considered to be not significant.

Practical effect of the K3 Proposed Development + other cumulative developments

As shown in Table 5.48 – 5.50 and discussed in paragraphs 5.13.33 to 5.13.36, the cumulative effects across the grid for the increase in K3 + other cumulative developments are considered to be not significant.

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WKN Proposed Development + other cumulative developments

As shown in Table 5.48 – 5.50 and discussed in paragraphs 5.13.33 to 5.13.36, the cumulative effects across the grid for the WKN Proposed Development + other cumulative developments are considered to be not significant.

WKN Proposed Development + K3 Proposed Development + other cumulative developments.

As shown in Table 5.48 – 5.50 and discussed in paragraphs 5.13.33 to 5.13.36, the cumulative effects across the grid for the WKN Proposed Development + K3 Proposed Development + other cumulative developments are considered to be not significant.

WKN Proposed Development + practical effect of the K3 Proposed Development + other cumulative developments.

As shown in Table 5.48 – 5.50 and discussed in paragraphs 5.13.33 to 5.13.36, the cumulative effects across the grid for the WKN Proposed Development + increase in K3 + other cumulative developments are considered to be not significant.

When considering the cumulative effects of traffic-related and stack emissions at sensitive receptors, the cumulative effects are considered to be not significant.

5.14 Summary

A detailed air quality assessment predicting the potential effects of emissions generated during the construction and operation of the WKN and K3 Proposed Development has been undertaken.

Impacts during the construction, such as dust generation and plant vehicle emissions, are predicted to be of short duration and only relevant during the construction phase. The results of the risk assessment of construction dust impacts undertaken using the IAQM dust guidance, indicate that before the implementation of mitigation and controls, the risk of dust impacts will be medium. Implementation of the ‘highly recommended’ mitigation measures described in the IAQM construction dust guidance is likely to reduce the residual dust effects to a level categorised as “not significant”.

Stack emissions from the K3 and WKN Proposed Development have been assessed through detailed dispersion modelling using best practice approaches. The assessment has been undertaken based on a number of conservative assumptions. This is likely to result in an over-estimate of the contributions that will arise in practice from the facility. The results of dispersion modelling reported in this assessment indicate that predicted contributions and resultant environmental concentrations of all pollutants considered would be of ‘negligible’ significance.

The operational impact of the K3 and WKN Proposed Developments on existing receptors in the local area are predicted to be ‘negligible’ taking into account the changes in pollutant concentrations and absolute levels.

Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 5-74

Wheelabrator Technologies Inc Wheelabrator Kemsley Generating Station (K3) and Wheelabrator Kemsley North (WKN) Waste to Energy Facility DCO

The main dust mitigation measure is containment. Taking into account the fact that the processes would be largely contained, and the relative distance to sensitive receptors, the risk of dust impacts during operation is predicted to be not significant based on professional judgement.

The risk of odour and bioaerosol impacts has been assessed qualitatively using a source-pathway-receptor conceptual model. The likely odour and bioaerosol effect is negligible.

Overall the air quality effects of the K3 and WKN Proposed Developments, both separately and cumulatively, are not considered to be significant.

Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 5-75

Wheelabrator Technologies Inc Wheelabrator Kemsley Generating Station (K3) and Wheelabrator Kemsley North (WKN) Waste to Energy Facility DCO References

5.1 Council Directive 2010/75/EU of the European Parliament and of the Counciil on industrial emissions

5.2 OPSI, 2016, The Environmental Permitting (England and Wales) Regulations 2016.

5.3 Defra, 2010, The Air Quality Standards (England) Regulations

5.4 Council Directive 2008/50/EC of 21 May 2008 on ambient air quality and cleaner air for Europe

5.5 Defra, 2007, The Air Quality Strategy for England, Scotland, Wales and Northern Ireland. Volume 2.

5.6 WHO (2005) Air Quality Guidelines: Global Update 2005.

5.7 EPAQS (2005) Expert Panel on Air Quality Standards(www.defra.gov.uk/environment/airquality/panels/aqs/index.htm)

5.8 https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental- permit

5.9 Environment Agency (2010) Environmental Permitting Regulations (EPR) – H1 Environmental Risk Assessment, Annex K

5.10 EPUK & IAQM (January 2017) Land-Use Planning & Development Control: Planning For Air Quality

5.11 IAQM (2014) Guidance on the assessment of dust from demolition and construction

5.12 British Standard Institute (1983) BS 6069:Part 2:1983, ISO 4225-1980 Characterization of air quality. Glossary

5.13 Local Air Quality Management Technical Guidance, 2016 (LAQM.TG16)

5.14 Drawn from Defra Maps at http://uk-air.defra.gov.uk/data/laqm-background- maps?year=2017

5.15 Environment Agency (2007) Review of methods for NO to NO2 conversion in plumes at short ranges

5.16 Environment Agency (undated) Conversion Ratios for NOx and NO2

5.17 Environment Agency, Review of Methods to Measure Bioaerosols at Composting Sites, Science Report SC040021/SR3, ISBN 978-1-84911-041-9 (2009)

5.18 Environment Agency (2010) Composting and Potential Health Effects from Bioaerosols: our Interim Guidance for Permit Applications, Position Statement 031, Version 1.0, 1st November 2010.

5.19 Environment Agency, Development of Amenity Risk Assessments at Organic Waste Treatment Facilities, Science Report SC040021/SR1, ISBN 978-1-84432-778-2 (2008)

Environmental Statement Volume 1 – September 2019 Ref: EN010083 – Document 3.1 Page 5-76

Wheelabrator Technologies Inc Wheelabrator Kemsley Generating Station (K3) and Wheelabrator Kemsley North (WKN) Waste to Energy Facility DCO

5.20 IOM Consulting Ltd (2008) Exposure-response relationships for bioaerosol emissions from waste treatment processes

5.21 DHA Environment (2011) Proposed Anaerobic Digestor Kemsley DCH/7471

5.22 wyg (2018) Proposed Standing Reserve Power Plant at Eurolink Industrial Estate, Castle Road, Sittingbourne, Kent

5.23 Environmental Compliance Limited (2014) Air Quality Assessment of Emissions from the Proposed Garden of England Energy Facility

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Appendix 5.2: Air Quality – Stack Height Determination for WKN

Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy Facility DCO

September 2019 -Submission Version PINS ref: EN010083

Appendix 5.2: Stack Height Determination for WKN

A stack height determination has been undertaken for WKN to establish the height at which there is minimal additional environmental benefit associated with the cost of further raising the stack. A stack height determination was undertaken for K3 in the 2010 ES.

The Environment Agency removed their detailed guidance, Horizontal Guidance Note EPR H1 [1], for undertaking risk assessments on 1 February 2016; however, the approach used here by RPS is consistent with that EA guidance which required the identification of “an option that gives acceptable environmental performance but balances costs and benefits of implementing it.”

The emissions data used in the stack height determination are summarised in Chapter 5: Air Quality, Section 5.3. Simulations have been run using ADMS 5 to determine what stack height is required to provide adequate dispersion/dilution and to overcome local building wake effects.

The stack height determination considers ground level concentrations over the averaging periods relevant to the air quality assessment, together with the full range of all likely meteorological conditions through the use of five years of hourly sequential meteorological data from Gravesend. The model was run for a range of stack heights between 80 m to 110 m, at 5 m increments.

The dispersion modelling for the purposes of stack height determination assumed a domain of 20 km by 20 km centred on the proposed development and with a grid spacing of 200 m. Results have been reported for the location where the highest concentration is predicted. This is considered a robust and conservative approach.

The predicted Process Contributions (PCs) as a percentage of the relevant Environmental Assessment Level (EAL) have been plotted against height in Graph 5.2.1 (at long-term emission limits) and Graph 5.2.2 (at short-term emission limits) to indicate if there is a height beyond which the benefit from further increases in stack height are diminished. The PCs as a percentage of the relevant EALs are provided in Table 5.2.1 and Table 5.2.2 respectively.

Graph 5.2.1: Maximum Predicted Process Contribution as Percentage of EAL vs Stack Height at Long-term IED Limits

Pollutant Concentration as % of EAL vs Height 5.0

4.5

4.0

3.5

3.0

2.5

2.0 PC as Percentage of EAL

1.5

1.0

0.5

0.0 80 85 90 95 100 105 110 Stack Height (m) Annual mean NO2 NO2 99.79 hourly mean CO 8 hour running mean SO2 15 minute mean Max 1 hour HCl Annual mean PM10 PM10 90.41 daily mean 99.18 daily mean SO2 99.73rd percentile hourly mean SO2

Graph 5.2.2: Maximum Predicted Process Contribution as Percentage of EAL vs Stack Height at Short-term IED Limits

Pollutant Concentration as % of EAL vs Height 12.0

10.0

8.0

6.0 PC as Percentage of EAL 4.0

2.0

0.0 80 85 90 95 100 105 110 Stack Height (m) NO2 99.79 hourly mean CO 8 hour running mean SO2 15 minute mean Max 1 hour HCl PM10 90.41 daily mean 99.18 daily mean SO2

Table 5.2.1 Maximum Predicted Process Contributions as a Percentage of the Relevant EAL at each Stack Height Modelled – Long-term IED Concentration Limits

Percentage of Environmental Assessment Level (%) Environmental Assessment 40 50 750 50 350 10000 40 200 125 266 Level (μg.m-3) 90.41st 99.73rd Maximum 99.18th 99.9th 99.79th Annual- percentile Maximum Annual percentile 8-hour Annual percentile percentile Height (m) percentile mean PM10 daily hourly HCl mean SO2 hourly running mean NO2 daily 15-minute NO2 mean PM10 mean SO2 CO mean SO2 mean SO2 80 0.2 0.6 0.2 0.9 1.8 0.06 3.1 4.5 2.8 2.7 85 0.2 0.5 0.2 0.8 1.7 0.06 2.6 4.2 2.3 2.6 90 0.2 0.4 0.2 0.7 1.5 0.05 2.3 3.9 2.0 2.4 95 0.1 0.4 0.2 0.6 1.4 0.05 2.1 3.6 1.8 2.3 100 0.1 0.3 0.2 0.5 1.3 0.04 1.9 3.4 1.6 2.1 105 0.1 0.3 0.2 0.5 1.2 0.04 1.7 3.2 1.5 2.0 110 0.1 0.3 0.2 0.4 1.2 0.04 1.5 3.0 1.4 1.9 Cells are shaded grey where the predicted process contribution is above 1% of EAL for long-term average periods and 10% for short-term average periods.

Table 5.2.2 Maximum Predicted Process Contributions as a Percentage of the Relevant EAL at each Stack Height Modelled – Short-term IED Concentration Limits

Percentage of Environmental Assessment Level (%) Environmental Assessment 50 750 200 10000 350 125 266 Level (μg.m-3) 90.41st Maximum 99.73rd 99.18th 99.9th 99.79th percentile Maximum 8-hour percentile percentile percentile Height (m) percentile daily hourly HCl running hourly daily 15-minute NO2 mean PM10 CO mean SO2 mean SO2 mean SO2 80 1.7 1.5 9.1 0.12 7.1 11.1 10.8 85 1.4 1.4 8.4 0.11 6.6 9.0 10.2 90 1.2 1.4 7.9 0.10 6.1 8.2 9.7 95 1.1 1.2 7.2 0.09 5.6 7.1 9.2 100 1.0 1.2 6.9 0.09 5.2 6.5 8.5 105 1.0 1.1 6.3 0.08 5.0 5.9 8.1 110 0.9 1.1 5.9 0.08 4.7 5.4 7.6 Cells are shaded grey where the predicted process contribution is above 10% for short-term average periods.

Discussion

The results in Table 5.2.1 indicate that there are no heights below 110 m at which the impacts can be screened- out as insignificant based on the PC alone when the plant is operating at long-term IED concentration limits as the maximum predicted PC for annual-mean NO2 is above 1% at all heights.

-3 The ambient annual-mean NO2 concentration adopted for the assessment is 31.7 μg.m . When the maximum predicted PC at 80m for the annual-mean NO2 is added to the ambient NO2 concentration, the total Predicted

-3 -3 Environmental Concentration (PEC) is 32.9 μg.m at 80m. This is below the EAL of 40 μg.m for NO2. On that basis, and according to the EA guidance, the impacts would not be considered significant at 80 m or above.

The results in Table 5.2.2 indicate that the PC is above 10% of the EAL for heights below 90m.

Based on the results of the detailed stack height modelling and using professional judgement, an acceptable stack height for the assessment of the WKN Proposed Development is considered to 90 m and the detailed modelling undertaken in this report assumes a 90 m high stack.

It should be noted that this is based on the information available to date. The stack height may be subject to change and may increase as the detailed design for the WKN Proposed Development continues to evolve. The stack height will be confirmed as part of the formal submission to PINS in spring 2019.

References

1 Environment Agency (2010) Environmental Permitting Regulations (EPR) – H1 Environmental Risk Assessment, Annex K

Document 3.1 – ES Volume 2

Appendix 5.3: Air Quality – Additional Baseline Assessment

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September 2019 -Submission Version PINS ref: EN010083

Appendix 5.3: Additional Baseline Assessment

Chapter 5 sets out the background concentrations for the key combustion-related pollutants, NO2 and PM10. This Appendix sets out the background concentrations for other pollutants emitted from the WKN and K3 stacks.

Carbon Monoxide

In the absence of any local carbon monoxide (CO) monitoring, the background annual-mean concentration has been extracted from the Defra mapped background concentration estimate for the grid square of the site. A maximum daily running 8-hour mean of 542 μg.m-3 has been estimated as twice the annual-mean CO concentration in line with Environment Agency guidance [1].

Particulate Matter with a Mean Aerodynamic Diameter less than 2.5 μm (PM2.5)

In the absence of any local monitoring of particulate matter with a mean aerodynamic diameter less than 2.5

μm (PM2.5), the background annual-mean concentration has been extracted from the Defra mapped background concentration estimate for the grid square of the site of 10.6 μg.m-3.

Sulphur Dioxide

The nearest monitoring sulphur dioxide (SO2) monitor is located at Rochester and operated by Defra as part of the Automatic Urban Rural Network (AURN). The measured concentrations in the two most recent years are provided in Table 5.3.1. For each averaging period, the maximum measure concentration has been used in the assessment.

-3 Table 5.3.1: Measured SO2 Concentrations (μg.m )

-3 SO2 Concentration (μg.m ) Averaging Period 2016 2017 Maximum 15 minute (99.90th percentile) 22.14 8.22 22.14 1 hour (99.73th percentile) 15.67 6.30 15.67 24 hour (99.18th percentile) 8.00 2.96 8.00 Annual mean (1 hour) 2.10 1.17 2.10

For each averaging period, the maximum measured concentration has been used in the assessment.

Heavy Metals

The Heavy Metals Network monitors the concentrations in air, and the deposition rates of a range of metallic elements. The nearest monitor is located at Detling, approximately 15 km south west of the DCO site boundary. With the exception of mercury (Hg), the measured concentrations in the last full calendar year (2017) are provided in Table 5.3.2. Hg monitoring has ceased at Detling and the measurement from the most recent year of monitoring (2012) is provided instead. Table 5.3.2: Measured Metals Concentrations (ng.m-3)

Group Metal Concentration (ng.m-3) 1 Cd 0.123 Tl - 2 Hg 0.784 (2012) 3 As 0.778 Co 0.062 Cr 1.321 Cu 4.543 Mn 3.266 Ni 0.675 Pb 6.128 Sb - V 0.663

Polycyclic Aromatic Hydrocarbons (PAHs)

The polycyclic aromatic hydrocarbon (PAH) network monitors ambient concentrations of PAHs at 31 sites in the UK. Gaseous and solid PAHs are monitored at Harwell. The most recent available measurements from Harwell are provided in Table 5.3.3.

Table 5.3.3: Annual-mean PAHs Concentrations (ng.m-3)

Site Name 2011 2012 2013 2014 Maximum Harwell (solid and gas) 0.062 0.084 0.096 0.043 0.096

The maximum measured concentration monitored of 0.096 μg.m-3 has been used within the assessment.

Hydrogen Chloride (HCl)

Hydrogen chloride (HCl) is monitored as part of the Acid Gas and Aerosol Network, part of the UK Eutrophying and Acidifying Pollutants (UKEAP) Network. The nearest monitoring location is Detling. The maximum hourly- mean concentrations in the most recent years of measurements from Detling are provided in Table 5.3.4. (Note that monitoring ceased at Detling in 2016).

Table 5.3.4: Measured HCl Concentrations (μg.m-3) at Detling

Site Name 2012 2013 2014 2015 Maximum Detling 0.81 0.78 1.16 0.62 1.16

The maximum measured concentration of 1.16 μg.m-3 has been used within the assessment. Hydrogen Fluoride

The Expert Panel on Air Quality Standards (EPAQS) was set up in 1991 to provide independent advice on air quality issues. In 2005 it published a draft report entitled 'Guidelines for halogen and hydrogen halides in ambient air for protecting human health against acute irritancy effects’ [2]. The report noted that only a small number of measurements of ambient concentrations of hydrogen fluoride have been made in the UK. All of these have been made in the vicinity of three industrial plants. Many samples were below the limit of detection; however, measurable values were in the range 0.05 to 3.5 μg.m-3 as approximate monthly averages. The report concluded that it would be reasonable to expect maximum 1 hour mean hydrogen fluoride concentrations to reach about 2.46 μg.m-3 at rural sites exposed to coal-fired power station plumes.

Polychlorinated Biphenyls (PCBs)

PCB concentration data are currently available from five sites in the UK that form the Toxic Organic Micropollutants (TOMPS) network. The closest site urban background site is Nobel House in London. Table 5.3.5 present the most recent available years of monitoring data at London for PCBs [3].

Table 5.3.5: Annual-Mean Concentrations (pg.m-3) of Polychlorinated Biphenyls

Site Name 2012 2013 2014 2015 2016 Average Nobel House 83.2 83.2 107.0 111.3 118.9 100.7

The average annual-mean concentration of PCBs of 100.7 pg.m-3 has been used within the assessment.

Dioxins and Furans

Dioxins and Furans concentration data from the TOMPS network Nobel House site are provided in Table 5.3.6.

Table 5.3.6: Annual-Mean Concentrations (fg.m-3) of Dioxins and Furans

Site Name 2012 2013 2014 2015 2016 Average Nobel House 15.5 3.5 2.9 5.5 24.3 10.3

The average annual-mean concentration of dioxins and furans of 10.3 fg.m-3 has been used within the assessment. Ammonia (NH3)

NH3 is monitored as part of the Ammonia Network, part of the UKEAP Network. The nearest monitoring location is Detling. The maximum hourly-mean concentrations in the most recent years of measurements from Detling are provided in Table 5.3.7.

-3 Table 5.3.7: Measured NH3 Concentrations (μg.m ) at Detling

Site Name 2014 2015 2016 2017 Maximum Detling 0.98 0.96 1.11 0.90 0.99

The maximum measured concentration of 0.99 μg.m-3 has been used within the assessment.

References

1 https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit

2 Expert Panel on Air Quality Standards: guidelines for halogen and hydrogen halides in ambient air for protecting human health against acute irritancy effects. Draft consultation document. Defra 2005 Available at http://www.defra.gov.uk/corporate/consult/airqual-halogen/index.htm

3 http://www.defra.gov.uk/evidence/statistics/environment/airqual/download/xls/aqtb29.xls Document 3.1 – ES Volume 2

Appendix 5.4: Air Quality - Assessment of Impacts on Ecological Receptors

Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy Facility DCO

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Appendix 5.4: Assessment of Ecological Impacts

The following European designated nature conservation sites, within 10 km of the Application Site, have been identified:

• The Swale Special Protection Area (SPA); • The Swale Ramsar; • Medway Estuary and Marshes SPA; • Medway Estuary and Marshes Ramsar; • Thames Estuary and Marshes SPA; • Thames Estuary and Marshes Ramsar; • Queensdown Warren Special Area of Conservation (SAC); and • Outer Thames Estuary SPA.

The following nationally designated sites, within 2 km of the Application Site, have also been identified: • The Swale SSSI; • Milton Creek LWS; and. • Elmley NNR.

For information, the Medway Estuary and Marshes SSSI is 2.9 km from the Application Site (i.e. more than 2 km away) and has been excluded from the assessment. The Swale Marine Conservation Zone (MCZ) has also been excluded as there is no requirement to assess air quality impacts at waterbodies/MCZs.

Approach This approach to this assessment considers the IAQM ‘A guide to the assessment of air quality impacts on designated nature conservation sites’. Concentrations of NOx, SO2 and Ammonia have been predicted using the same model as used in the assessment of impacts at human-health receptors. Modelling has been undertaken for a grid of receptor points, with a grid spacing of 200 m, across each identified nature conservation site. The receptor grid points have been modelled at ground level. To ensure that the assessment is conservative, the maximum PC for WKN and K3 (0 – 75MW) the K3 Proposed Development at each site and for all the meteorological datasets has been identified and is presented in this Appendix.

Critical Levels Critical levels are maximum atmospheric concentrations of pollutants for the protection of vegetation and ecosystems and are specified within relevant European air quality directives and corresponding UK air quality regulations. PCs and, where appropriate, PECs of NOx, SO2 and NH3 have been calculated for comparison with the relevant critical level. Background concentrations at each designated site have been derived from the UK Air Pollution Information System (APIS) database [1].

JAR10341 rpsgroup.com/uk March 2019 | Rev0

Critical Loads Critical loads refer to the quantity of pollutant deposited, below which significant harmful effects on sensitive elements of the environment do not occur, according to present knowledge. Nutrient nitrogen deposition and acid deposition are considered in this Appendix.

Critical Loads – Nutrient N Deposition Percentage contributions to nutrient nitrogen deposition have been derived from the modelled NOx concentrations. Deposition rates have been calculated using empirical methods recommended by the Environment Agency, as follows:

-2 -1 1. The dry deposition flux (µg.m .s ) has been calculated by multiplying the ground level NO2 concentrations (μg.m-3) by the deposition velocity of 0.003 m.s-1 for forests/tall habitats and 0.0015 m.s-1 for grassland/short habitats.

2. Units of µg.m-2.s-1 have been converted to units of kg.ha-1.year-1 by multiplying the dry deposition flux by the standard conversion factor of 96 for NOx.

3. Predicted contributions to nitrogen deposition have been calculated and compared with the relevant critical load range for the habitat types associated with the designated site. These have been derived from the APIS database.

Critical Loads – Acidification The acid deposition rate, in equivalents keq.ha-1.year-1, has been calculated by multiplying the dry deposition flux (kg.ha-1.year-1) by a conversion factor of 0.071428 for N. This takes into account the degree to which a chemical species is acidifying, calculated as the proportion of N within the molecule.

Wet deposition in the near field is not significant compared with dry deposition for N [2] and therefore for the purposes of this assessment, wet deposition has not been considered.

Predicted contributions to acid deposition have been calculated and compared with the minimum critical load function for the habitat types associated with the designated site as derived from the APIS database.

Significance Criteria

Maximum PCs and PECs of NOx, SO2, NH3 and N/acid deposition have been compared against the relevant EQS for the relevant habitat type/interest feature. The Environment Agency guidelines [3] state that:

"To screen out a PC for any substance so that you don’t need to do any further assessment of it, the PC must meet both of the following criteria:

-the short-term PC is less than 10% of the short-term environmental standard

-the long-term PC is less than 1% of the long-term environmental standard

If you meet both of these criteria you don’t need to do any further assessment of the substance.

JAR10341 rpsgroup.com/uk March 2019 | Rev0

If you don’t meet them you need to carry out a second stage of screening to determine the impact of the PEC."

It continues by stating that:

"If your long-term PC is greater than 1% and your PEC is less than 70% of the long-term environmental standard, the emissions are insignificant – you don’t need to assess them any further."

Where potentially significant impacts have been identified, the impacts have been passed to the project’s ecologist to allow the significance of the likely effect to be determined.

Results

The ambient NOx, SO2 and NH3 concentrations and existing deposition rates have been obtained from APIS. The highest deposition rates have been obtained taking into account the various habitats across the sites. The lowest critical loads for nitrogen deposition and acid deposition have been also obtained from APIS [4].

The maximum predicted annual-mean NOx, SO2 and NH3 concentrations are compared with the critical level in Tables 5.4.1, 5.4.2 and 5.4.3. The maximum predicted nutrient N deposition rates are compared with the critical load in Table 5.4.4. The maximum predicted acid deposition rates are compared with the critical load function in Table 5.4.5. Only Queendown Warren is sensitive to acid deposition and the other designated sites have not been presented in this table.

For the Outer Thames Estuary SPA, APIS describes the habitat as inshore sublittoral sediment, which provides wintering for the red-throated diver. APIS states that this habitat is not sensitive to increases in NOx, SO2 or

NH3 concentrations, nitrogen deposition or acid deposition. As such, this site has not been considered further in the assessment.

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Table 5.4.1 Predicted Annual-Mean NOx Concentrations at Designated Sites CL WKN + K3 PEC - -3 WKN + K3 PC WKN + K3 PC/CL WKN + K3 PEC - Designated Site (μg.m AC (µg.m ) -3 -3 as % of CL (µg.m (μg.m ) (%) (µg.m ) 3 3) )

The Swale SPA/Ramsar/SSSI/Elmley NNR/Milton Creek LWS 12.3 3.2 11 15.5 52

Medway Estuary and Marshes SPA/Ramsar 24.4 0.4 1 24.8 83 30 Thames Estuary and Marshes SPA/Ramsar 18.3 0.1 0 18.4 61

Queendown Warren SAC 18.7 0.1 0 18.9 63

Table 5.4.2 Predicted Annual-Mean SO2 Concentrations at Designated Sites CL WKN + K3 PEC - -3 WKN + K3 PC WKN + K3 PC/CL WKN + K3 PEC - Designated Site (μg.m AC (µg.m ) -3 -3 as % of CL (µg.m (μg.m ) (%) (µg.m ) 3 3) )

The Swale SPA/Ramsar/SSSI/Elmley NNR/Milton Creek LWS 0.29 0.80 4 1.09 5

Medway Estuary and Marshes SPA/Ramsar 0.36 0.09 0 0.45 2 20 Thames Estuary and Marshes SPA/Ramsar 0.32 0.03 0 0.35 2

Queendown Warren SAC 0.34 0.04 0 0.38 2

Table 5.4.3 Predicted Annual-Mean NH3 Concentrations at Designated Sites CL WKN + K3 PC WKN + K3 WKN + K3 WKN + K3 Designated Site AC -3 -3 (μg.m-3) (μg.m ) PC/CL (%) PEC (μg.m ) PEC/CL (%)

The Swale SPA/Ramsar/SSSI/Elmley NNR/Milton Creek LWS 0.88 0.080 3 0.96 32

Medway Estuary and Marshes SPA/Ramsar 0.77 0.009 0 0.78 26 3 Thames Estuary and Marshes SPA/Ramsar 0.76 0.003 0 0.76 25

Queendown Warren SAC 1.01 0.004 0 1.01 34

JAR10341 March 2019 | Rev0 Notes: The Swale SPA, Medway Estuary and Marshes SPA and Thames Estuary and Marshes SPA all cover the same geographical areas as the corresponding Ramsar and SSSI designations. Therefore, the values set out in Tables 5.4.1 to 5.4.3 represent the pollutant concentrations at all of these sites. Elmley NNR is within The Swale SPA/Ramsar/SSSI. APIS does not provide data for NNRs so the ambient concentrations and critical levels/loads have been assumed to be the same as The Swale SPA. Milton Creek LWS is an extension of the Swale SPA and the project’s ecologist has advised that the same habitats, ambient concentrations and critical levels/loads apply. The Milton Creek LWS is mostly upwind of the Proposed Development; the nearest part of the LWS downwind of the site is to the east and covers a similar geographic area as the Swale SPA/Ramsar/SSSI. Milton Creek is a LWS and so the impact would only be significant if the PC exceeds 100% of the CL. Therefore considering the LWS to be the same as the Swale SPA/RAMSAR/SSSI is a conservative approach. Consistent with the Institute of Air Quality Management’s “A guide to the assessment of air quality impacts on designated nature conservation sites” [Error! Bookmark not defined.], the PC as a % of the CL has been rounded to the nearest integer.

Table 5.4.4 Predicted Nutrient N Deposition at Designated Sites WKN + CL WKN + AC (kgN.ha- WKN + K3 PC WKN + K3 K3 PEC K3 -1 - Designated Site Interest Feature (kgN.ha .yr 1 -1 .yr ) (kgN.ha-1.yr-1) PC/CL (%) (kgN.ha- PEC/CL 1) 1.yr-1) (%) Breeding Lapwing 20 14.2 0.9 4 15.1 75 Ringed plover 20 14.2 0.9 4 15.1 75 Eurasian reed warbler 15 14.2 0.9 6 15.1 101 Eurasian curlew 20 14.2 0.9 4 15.1 75 Reed bunting 15 14.2 0.9 6 15.1 101 Dark-bellied brent goose 20 14.2 0.9 4 15.1 75 Common shelduck 20 14.2 0.9 4 15.1 75 The Swale SPA/Elmley Eurasian teal 20 14.2 0.9 4 15.1 75 NNR/Milton Creek LWS Mallard Not available 14.2 0.9 - 15.1 - Common moorhen Not available 9.8 0.9 - 10.7 - Gadwall Not available 9.8 0.9 - 10.7 - Grey plover 20 14.2 0.9 4 15.1 75 Dunlin 20 14.2 0.9 4 15.1 75 Common coot Not available 9.8 0.9 - 10.7 - Common redshank 20 14.2 0.9 4 15.1 75 Eurasian oystercatcher 20 14.2 0.9 4 15.1 75 Medway Estuary and Common tern 8 13.2 0.10 1 13.3 166 Marshes SPA Red-throated diver Not sensitive 10.8 0.10 - 10.9 - Eurasian curlew 20 13.2 0.10 1 13.3 67

JAR10341 March 2019 | Rev0 WKN + CL WKN + - WKN + K3 PC K3 PEC K3 -1 - AC (kgN.ha WKN + K3 Designated Site Interest Feature (kgN.ha .yr 1 -1 .yr ) (kgN.ha-1.yr-1) PC/CL (%) (kgN.ha- PEC/CL 1) 1.yr-1) (%) Common greenshank 20 13.2 0.10 1 13.3 67 Little tern 8 13.2 0.10 1 13.3 166 Hen harrier 10 13.2 0.10 1 13.3 133 Merlin 10 13.2 0.10 1 13.3 133 Ringed plover 20 13.2 0.10 1 13.3 67 Short-eared owl 10 Not available 0.10 1 - - Great crested grebe 20 13.2 0.10 1 13.3 67 Great cormorant Not available 13.2 0.10 - 13.3 - Dark-bellied brent goose 20 13.2 0.10 1 13.3 67 Eurasian teal 20 13.2 0.10 1 13.3 67 Mallard 20 13.2 0.10 1 13.3 67 Northern shoveler Not available 13.2 0.10 - 13.3 - Common shelduck 20 13.2 0.10 1 13.3 67 Eurasian wigeon 20 13.2 0.10 1 13.3 67 Northern pintail 20 13.2 0.10 1 13.3 67 Common pochard 20 13.2 0.10 1 13.3 67 Eurasian oystercatcher 20 13.2 0.10 1 13.3 67 Pied avocet 20 13.2 0.10 1 13.3 67 Grey plover 20 13.2 0.10 1 13.3 67 Red knot 20 13.2 0.10 1 13.3 67 Dunlin 20 13.2 0.10 1 13.3 67 Black-tailed godwit 20 13.2 0.10 1 13.3 67 Common redshank 20 13.2 0.10 1 13.3 67 Ruddy turnstone 20 13.2 0.10 1 13.3 67 Tundra swan Not sensitive 13.2 0.10 - 13.3 - Common kingfisher Not available 10.8 0.10 - 10.9 - Thames Estuary and Ringed plover 8 12.1 0.03 0 12.1 151 Marshes SPA Hen harrier 10 12.1 0.03 0 12.1 121 Pied avocet 20 12.1 0.03 0 12.1 60 JAR10341 March 2019 | Rev0 WKN + CL WKN + - WKN + K3 PC K3 PEC K3 -1 - AC (kgN.ha WKN + K3 Designated Site Interest Feature (kgN.ha .yr 1 -1 .yr ) (kgN.ha-1.yr-1) PC/CL (%) (kgN.ha- PEC/CL 1) 1.yr-1) (%) Grey plover 20 12.1 0.03 0 12.1 60 Red knot 20 12.1 0.03 0 12.1 60 Dunlin 20 12.1 0.03 0 12.1 60 Black-tailed godwit 20 12.1 0.03 0 12.1 60 Common redshank 20 12.1 0.03 0 12.1 60 Queendown Warren SAC Semi-natural dry grasslands and scrubland facies 0.04 0 15 15.4 15.4 103 on calcareous substrates Intertidal habitats (coastal saltmarsh) 20 14.2 0.9 4 15.1 75 Saltmarsh (coastal saltmarsh) 20 14.2 0.9 4 15.1 75 The Swale Ramsar/SSSI Shingle & sea cliff (dunes, shingle & machair) 10 14.2 0.9 4 15.1 75 Arable (horticultural & arable) Not sensitive - - - - - Standing water (standing open water) No CL - - - - - Waste land, industrial (no corresponding APIS Not sensitive - - - - - Intertidal habitatshabitat) (coastal saltmarsh) 20 13.2 0.1 1 13.3 67 Saltmarsh (coastal saltmarsh) 20 13.2 0.1 1 13.3 67 Shingle & sea cliff (dunes, shingle & machair) 10 13.2 0.1 1 13.3 133 Medway Estuary and Wet grassland (grazing marsh) 20 13.2 0.1 1 13.3 67 Marshes Ramsar Dry grassland (grazing marsh) 20 13.2 0.1 1 13.3 67 Bogs, marshes, fens (fen, marsh & swamp) 15 13.2 0.1 1 13.3 89 Standing water (standing open water) No CL - - - - - Intertidal habitats (coastal saltmarsh) 20 13.2 0.1 1 13.3 67 Intertidal habitats (coastal saltmarsh) 20 12.1 0.03 0 12.1 60 Saltmarsh (coastal saltmarsh) 20 12.1 0.03 0 12.1 60 Thames Estuary and Shingle & sea cliff (dunes, shingle & machair) 10 12.1 0.03 0 12.1 121 Marshes Ramsar Wet grassland (grazing marsh) 20 12.1 0.03 0 12.1 60 Dry grassland (grazing marsh) 20 12.1 0.03 0 12.1 60 Bogs, marshes, fens (fen, marsh & swamp) 15 12.1 0.03 0 12.1 80 Standing water (standing open water) No CL - - - - - Note:

JAR10341 March 2019 | Rev0 Critical loads (CLs) for nutrient nitrogen deposition are provided as a range. In this case, the lower limit of the CL range has been used in the assessment. Consistent with the Institute of Air Quality Management’s “A guide to the assessment of air quality impacts on designated nature conservation sites” [Error! Bookmark not defined.], the PC as a % of the CL has been rounded to the nearest integer.

Table 5.4.5 Predicted Acid Deposition at Designated Sites

Critical Loads (keq.ha-1.yr-1) WKN + K3 PC (keq.ha-1.yr-1)

WKN + K3 Designated Site Interest Feature PC/CLF (%)

Min N Max N Max S N S

Semi-natural dry grasslands Queendown Warren SAC and scrubland facies on 0.856 4.856 4 0.003 0.004 0 calcareous substrates. Notes: CLF = Critical Load Function. Consistent with the Institute of Air Quality Management’s “A guide to the assessment of air quality impacts on designated nature conservation sites” [Error! Bookmark not defined.], the PC as a % of the CL has been rounded to the nearest integer.

JAR10341 March 2019 | Rev0 Annual-mean NOx

The maximum annual-mean NOX WKN + K3 PCs only exceeds 1% of the critical level at the Swale SPA/SSSI/Ramsar; the effects can be screened out as insignificant at the other sites. At the Swale SPA/SSSI/Ramsar the WKN + K3 PC is 11% of the critical level and based on the PC alone the impact is potentially significant; however, when the AC is added to the PC, the PEC is only 52% of the critical level of 30 μg.m-3 and the impacts can be screened out as insignificant.

Annual-mean SO2

The maximum annual-mean SO2 WKN + K3 PCs only exceeds 1% of the critical level at the Swale SPA/SSSI/Ramsar and the effects can be screened out as insignificant at the other sites. At the Swale SPA/SSSI/Ramsar the WKN + K3 PC is 4% of the critical level and based on the PC alone the impact is potentially significant; however, when the AC is added to the PC, the PEC is only 5% of the critical level of 20 μg.m-3 and the impacts can be screened out as insignificant.

Annual-mean NH3

The maximum annual-mean NH3 WKN + K3 PCs only exceeds 1% of the critical level at the Swale SPA/SSSI/Ramsar and the effects can be screened out as insignificant at the other sites. At the Swale SPA/SSSI/Ramsar the WKN + K3 PC is 3% of the critical level and based on the PC alone the impact is potentially significant; however, when the AC is added to the PC, the PEC is only 32% of the critical level of 3 μg.m-3 and the impacts can be screened out as insignificant.

Nutrient N Deposition

The maximum nitrogen deposition PC exceeds 1% of the critical load at several interest features however when the AC is added to the PC, the PECs are below the critical loads for all but two interest features and the impacts can be screened out as insignificant. For Eurasian reed warbler and Reed bunting, the PEC is 101% of the critical load and the impacts can’t be screened out. The results have been passed to the projects’ ecologist to assess the effects.

Acid Deposition

The maximum acid deposition PC is less than 1% of the critical load and the impacts can be screened out as insignificant.

JAR10341 March 2019 | Rev0 rpsgroup.com/uk

Cumulative Impacts Section 5.13 of Chapter 5: Air Quality sets outs the cumulative developments considered for this assessment. There are four developments where there was sufficient detail to allow a PC to be added to give a cumulative PEC for ecological receptors:

• Kemsley K4 CHP PC (EN010090 (18/501923/ADJ)) • Kemsley AD (SW/11/1291) • Reserve Power Plant PC (18/500393/FULL) • Garden of England Energy Facility (15/500348/COUNTY)

The PCs for each of these four developments are outlined in the table below. This has been added to the maximum PEC to give a Cumulative PEC.

Table 5.4.6 Predicted Annual-Mean NOx Concentrations at Designated Sites Garden of Cum Cu Kemsley Reserve WKN Kemsley England ulativ mul Cumulati AC Proposed K4 CHP PC Power CL PC AD Energy Cumulati e PC ativ ve PEC Designated Site (µg.m- K3 PC (EN010090 Plant PC -3 (μg.m (SW/11/1 Facility ve PC as % e as % of (μg.m ) 3) (μg.m-3) (18/501923/ (18/500393/ -3) 291) (15/500348/ of CL PE CL ADJ)) FULL) COUNTY) C

The Swale SPA/Ramsar/SSSI/Elmley 12.3 2.0 1.3 0.8 1.38 2.23 1.33 9.0 30 21.3 71 NNR/Milton Creek LWS

Medway Estuary and Marshes 24.4 0.2 0.2 0.1 0.05 - 0.11 0.6 2 25.1 84 SPA/Ramsar 30

Thames Estuary and Marshes 18.3 0.1 0.1 0.1 0.01 - 0.02 0.3 1 18.5 62 SPA/Ramsar

Queendown Warren SAC 18.7 0.1 0.1 0.1 0.01 - 0.02 0.2 1 18.9 63

Table 5.4.7 Predicted Annual-Mean SO2 Concentrations at Designated Sites Kemsley Kemsle Garden of CL AC Propo WK Reserve Cumul Cumul Cumul Cumul K4 CHP y AD England Designated Site (μg. (µg. sed N Power ative ative ative ative -3 PC (SW/11/ Energy m-3) m ) K3 PC PC Plant PC PC PC as PEC PEC as (EN010090 1291) Facility

JAR10341 March 2019 | Rev0 (μg.m- (μg. (18/501923 (18/500393/ (15/500348/C % of % of 3) m-3) /ADJ)) FULL) OUNTY) CL CL

The Swale SPA/Ramsar/SSSI/Elmley 0.2 0.3 0.49 - - - 0.066 0.89 4 1.18 6 NNR/Milton Creek LWS 9 3

Medway Estuary and Marshes 0.3 0.0 0.04 - - - 0.0053 0.10 0 0.46 2 SPA/Ramsar 6 5 20 Thames Estuary and Marshes 0.3 0.0 0.01 - - - 0.001 0.03 0 0.35 2 SPA/Ramsar 2 2

0.3 0.0 0.02 - - - 0.001 0.04 0 0.38 2 Queendown Warren SAC 4 2

Table 5.4.8 Predicted Annual-Mean NH3 Concentrations at Designated Sites Kemsley Garden of Propo Reserve Cumul Cumul WK K4 CHP Kemsle England CL AC sed Power Cumul ative Cumul ative N PC y AD Energy Designated Site (μg. K3 PC Plant PC ative PC as ative PEC as (μg. (μg. (EN010090 (SW/11/ Facility -3 m-3) (μg.m- (18/500393/ PC % of PEC % of m ) m-3) (18/501923 1291) (15/500348/C 3) FULL) CL CL /ADJ)) OUNTY)

The Swale SPA/Ramsar/SSSI/Elmley 0.8 0.0 0.05 - - - 0.33 0.412 14 1.29 43 NNR/Milton Creek LWS 8 33

Medway Estuary and Marshes 0.7 <0.00 0.0 - - - 0.026 0.035 1 0.81 27 SPA/Ramsar 7 5 05 3 Thames Estuary and Marshes 0.7 <0.00 0.0 - - - 0.005 0.008 0 0.77 26 SPA/Ramsar 6 5 02

1.0 <0.00 0.0 - - - 0.005 0.009 0 1.02 34 Queendown Warren SAC 1 5 02 Notes: The Swale SPA, Medway Estuary and Marshes SPA and Thames Estuary and Marshes SPA all cover the same geographical areas as the corresponding Ramsar and SSSI designations. Therefore, the values set out in Table 5.4.6, 5.4.7 and 5.4.8 represent the concentrations at all of these sites. Elmley NNR is within The Swale SPA/Ramsar/SSSI. APIS does not provide data for NNRs so the ambient concentrations and critical levels/loads have been assumed to be the same as The Swale SPA. Milton Creek LWS is an extension of the Swale SPA and the project’s ecologist has advised that the same habitats, ambient concentrations and critical levels/loads apply. The Milton Creek LWS is mostly upwind of the Proposed Development; the nearest part of the LWS downwind of the site is to the east and covers a similar geographic area as the Swale SPA/Ramsar/SSSI.

JAR10341 March 2019 | Rev0 Milton Creek is a LWS and so the impact would only be significant if the PC exceeds 100% of the CL. Therefore considering the LWS to be the same as the Swale SPA/RAMSAR/SSSI is a conservative approach. Consistent with the Institute of Air Quality Management’s “A Guide to the Assessment of Air Quality Impacts on Designated Nature Conservation Sites”, the PC as a % of the CL has been rounded to the nearest integer.

Table 5.4.9 Predicted Nutrient N Deposition at Designated Sites Prop Kemsley WKN Garden of CL AC osed K4 CHP Reserve Cumul Cumul PC Kemsle England Cumul Cumul (kgN K3 PC Power ative ative Interest (kgN y AD Energy ative ative Designated Site - .ha- PC (kgN (EN01009 Plant PC PC PEC Feature .ha - (SW/11/ Facility PC/CL PEC/C 1 - 1.yr- .ha 0 (18/500393 (kgN.h .yr (kgN. 1 - (kgN.h 1 .yr 1291) (15/500348/C -1 -1 (%) L (%) 1) ) ha- (18/50192 /FULL) a .yr ) a-1.yr-1) 1) OUNTY) 1.yr-1) 3/ADJ))

Breedin 20 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 24 19.0 95 g Ringed 20 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 24 19.0 95 Lapwingplover Eurasia 15 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 32 19.0 127 n reed Eurasia 20 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 24 19.0 95 nwarbler curlew Reed 15 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 32 19.0 127 buntingDark- bellied 20 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 24 19.0 95 brent Commo 20 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 24 19.0 95 goosen Eurasia 20 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 24 19.0 95 shelducn teal The Swale SPA/Elmley NNR/ Mallardk Not 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 - 19.0 - Milton Creek LWS avail Commo ableNot 9.8 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 - 14.6 - n avail moorhe able Gadwalln Not 9.8 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 - 14.6 - avail Grey able20 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 24 19.0 95 plover Dunlin 20 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 24 19.0 95 Commo Not 9.8 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 - 14.6 - n coot avail able Commo 20 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 24 19.0 95 Eurasian redshann 20 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 24 19.0 95 oystercak tcher JAR10341 March 2019 | Rev0 Prop Kemsley WKN Garden of CL AC osed K4 CHP Reserve Cumul Cumul PC Kemsle England Cumul Cumul (kgN K3 PC Power ative ative Interest (kgN y AD Energy ative ative Designated Site - .ha- PC (kgN (EN01009 Plant PC PC PEC Feature .ha - (SW/11/ Facility PC/CL PEC/C 1 - 1.yr- .ha 0 (18/500393 (kgN.h .yr (kgN. 1 - (kgN.h 1 .yr 1291) (15/500348/C -1 -1 (%) L (%) 1) ) ha- (18/50192 /FULL) a .yr ) a-1.yr-1) 1) OUNTY) 1.yr-1) 3/ADJ))

Commo 8 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 4 13.5 169 n tern Red- Not throated sensi 10.8 0.05 0.05 0.01 0.0005 - 0.19 0.3 - 11.1 - diver tive Eurasia 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 n curlew Commo 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 n Little 8 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 4 13.5 169 greenshtern Henank 10 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 3 13.5 135 harrier Merlin 10 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 3 13.5 135 Ringed 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 Shortplover- 10 Not 0.05 0.05 0.01 0.0005 - 0.19 0.3 3 - - eared avail owl Great 20 13.2able 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 Medway Estuary and crested Great Not Marshes SPA grebe 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 - 13.5 - cormora avail nt able Dark- 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 bellied Eurasia 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 nbrent teal Mallardgoose 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 Northern Not 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 - 13.5 - shoveler avail able Commo 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 n Eurasia 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 shelducn Northernk 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 wigeonpintail Commo 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 Eurasian pochardn 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 oysterca Pied tcher 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 avocet

Grey 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 plover Red 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 knot Dunlin 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 Black- 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 tailed Commogodwit 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 n Ruddy 20 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 2 13.5 68 turnstonredshan Tundra ek Not 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 - 13.5 - swan sensi Commo tive Not 10.8 0.05 0.05 0.01 0.0005 - 0.19 0.3 - 11.1 - n avail kingfish Ringed able er 8 12.1 0.02 0.02 0.01 0.0001 - 0.03 0.1 1 12.1 152 plover Hen 10 12.1 0.02 0.02 0.01 0.0001 - 0.03 0.1 1 12.1 121 harrier Pied 20 12.1 0.02 0.02 0.01 0.0001 - 0.03 0.1 0 12.1 61 Thames Estuary and avocet Grey 20 12.1 0.02 0.02 0.01 0.0001 - 0.03 0.1 0 12.1 61 Marshes SPA plover Red 20 12.1 0.02 0.02 0.01 0.0001 - 0.03 0.1 0 12.1 61 knot Dunlin 20 12.1 0.02 0.02 0.01 0.0001 - 0.03 0.1 0 12.1 61 Black- 20 12.1 0.02 0.02 0.01 0.0001 - 0.03 0.1 0 12.1 61 Commotailed godwit 20 12.1 0.02 0.02 0.01 0.0001 - 0.03 0.1 0 12.1 61 Semin - redshan Queendown Warren SAC natural dryk 15 15.4 0.02 0.02 0.01 0.0001 - 0.03 0.1 1 15.5 103 grasslan ds and Intertidalscrublan habitats 20 14.2 0.54 0.36 0.1 0.0174 1.92 1.87 4.8 24 4.8 95 The Swale Ramsar/SSSI d facies (coastalon Saltmar calcareosaltmars sh 20 14.2 0.54 0.36 0.1 0.0174 1.92 1.87 4.8 24 4.8 95 ush) substrat(coastal saltmarses JAR10341 h) March 2019 | Rev0 Prop Kemsley WKN Garden of CL AC osed K4 CHP Reserve Cumul Cumul PC Kemsle England Cumul Cumul (kgN K3 PC Power ative ative Interest (kgN y AD Energy ative ative Designated Site - .ha- PC (kgN (EN01009 Plant PC PC PEC Feature .ha - (SW/11/ Facility PC/CL PEC/C 1 - 1.yr- .ha 0 (18/500393 (kgN.h .yr (kgN. 1 - (kgN.h 1 .yr 1291) (15/500348/C -1 -1 (%) L (%) 1) ) ha- (18/50192 /FULL) a .yr ) a-1.yr-1) 1) OUNTY) 1.yr-1) 3/ADJ)) Shingle & sea 10 14.2 0.54 0.36 0.1 0.0174 1.92 1.87 4.8 48 4.8 190 cliff (dunes,Arable Not 14.2 0.54 0.36 0.1 0.0174 1.92 1.87 4.8 - 4.8 - (horticultshingle sensi Standinural& & tive No 14.2 0.54 0.36 0.1 0.0174 1.92 1.87 4.8 - 4.8 - machair)garable) water CL (standin Waste Not g open land, sensi 14.2 0.54 0.36 0.1 0.0174 1.92 1.87 4.8 - 4.8 - industriawater) tive Intertidall (no correspohabitats 20 13.2 0.05 0.05 0.01 0.0007 - 0.19 0.3 2 0.3 68 (coastalnding saltmarsSaltmarAPIS habitat)shh) 20 13.2 0.05 0.05 0.01 0.0007 - 0.19 0.3 2 0.3 68 (coastalShingle saltmars & sea 10 13.2 0.05 0.05 0.01 0.0007 - 0.19 0.3 3 0.3 135 cliffh) Medway Estuary and (dunes, Marshes Ramsar Wet shingle grasslan 20 13.2 0.05 0.05 0.01 0.0007 - 0.19 0.3 2 0.3 68 & d machair)Dry grasslan(grazing 20 13.2 0.05 0.05 0.01 0.0007 - 0.19 0.3 2 0.3 68 marsh) Bogs,d marshes(grazing 15 13.2 0.05 0.05 0.01 0.0007 - 0.19 0.3 2 0.3 90 marsh), fens Standin (fen, No 13.2 0.05 0.05 0.01 0.0007 - 0.19 0.3! - 0.2 - marshg water & CL (standinswamp) g open water)

JAR10341 March 2019 | Rev0 Prop Kemsley WKN Garden of CL AC osed K4 CHP Reserve Cumul Cumul PC Kemsle England Cumul Cumul (kgN K3 PC Power ative ative Interest (kgN y AD Energy ative ative Designated Site - .ha- PC (kgN (EN01009 Plant PC PC PEC Feature .ha - (SW/11/ Facility PC/CL PEC/C 1 - 1.yr- .ha 0 (18/500393 (kgN.h .yr (kgN. 1 - (kgN.h 1 .yr 1291) (15/500348/C -1 -1 (%) L (%) 1) ) ha- (18/50192 /FULL) a .yr ) a-1.yr-1) 1) OUNTY) 1.yr-1) 3/ADJ)) Intertidal habitats 20 13.2 0.05 0.05 0.01 0.0007 - 0.19 0.3 2 0.3 68 Intertidal(coastal saltmarshabitats 20 12.1 0.02 0.02 0.01 0.0002 - 0.03 0.1 0 0.1 61 h) (coastalSaltmar saltmarssh 20 12.1 0.02 0.02 0.01 0.0002 - 0.03 0.1 0 0.1 61 (coastalh) Shingle saltmars & sea h) 10 12.1 0.02 0.02 0.01 0.0002 - 0.03 0.1 1 0.1 121 cliff Thames Estuary and (dunes, Wet Marshes Ramsar shingle grasslan 20 12.1 0.02 0.02 0.01 0.0002 - 0.03 0.1 0 0.1 61 & d machair)Dry (grazing grasslan 20 12.1 0.02 0.02 0.01 0.0002 - 0.03 0.1 0 0.1 61 marsh) Bogs,d marshes(grazing 15 12.1 0.02 0.02 0.01 0.0002 - 0.03 0.1 0 0.1 81 marsh), fens Standin No (fen, 12.1 0.54 0.02- 0.01 -0.002 - 0.03 0.1 - 0.1 - g water CL marsh(standin & Note: swamp)g open Future AC is the AC from the APIS website plus the PC from K3 as permitted water) Critical loads (CLs) for nutrient nitrogen deposition are provided as a range. In this case, the lower limit of the CL range has been used in the assessment. Consistent with the Institute of Air Quality Management’s “A Guide to the Assessment of Air Quality Impacts on Designated Nature Conservation Sites”, the PC as a % of the CL has been rounded to the nearest integer.

Table 5.4.10 Predicted Acid Deposition at Designated Sites

JAR10341 March 2019 | Rev0 Garden of Cumulativ Kemsley K4 Reserve Kemsley England e PEC WKN PC CHP PC Power Plant Critical Loads AD Energy Cumulativ (keq.ha-1.yr- (EN010090 PC WKN + Cum (keq.ha-1.yr-1) (SW/11/12 Facility e PC 1) (18/501923/ (18/500393/ PC Increase in ulati 91) (15/500348/ Desig ADJ)) FULL) as % K3 PC/CLF ve nated Interest Feature COUNTY) of (%) PEC Site CLF as % (%) of Min Max Ma CLF N S N S N S N S N S N S N S N N x S

Semi-natural dry Queen grasslands and down 0.8 0.0 0.000 0.0 0.0 0.0 0.0 0.2 scrubland facies on 4.856 4 0.002 - - - 0.001 - 0 1.10 27 Warre 56 01 5 001 000 04 03 1 n SAC calcareous substrates. Notes: * Habitat in parenthesis is the corresponding APIS broad habitat for which critical loads are available # dune/shingle/marsh systems in this location are calcareous and therefore well buffered CLF = Critical Load Function. Consistent with the Institute of Air Quality Management’s “A Guide to the Assessment of Air Quality Impacts on Designated Nature Conservation Sites”, the PC as a % of the CL has been rounded to the nearest integer.

JAR10341 March 2019 | Rev0

Annual-mean NOx

The maximum annual-mean NOX cumulative PC only exceeds 1% of the critical level at the Swale SPA/SSSI/Ramsar and the Medway Estuary & Marshes SPA/Ramsar; the effects can be screened out as insignificant at the other sites. At the Swale SPA/SSSI/Ramsar and the Medway Estuary & Marshes SPA/Ramsar the cumulative PC is 30 and 2% of the critical level and based on the cumulative PCs alone the impact is potentially significant; however, when the AC is added to the PCs, the cumulative PECs are only 71 and 84% of the critical level of 30 μg.m-3 and the impacts can be screened out as insignificant.

Annual-mean SO2

The maximum annual-mean SO2 cumulative PC only exceeds 1% of the critical level at the Swale SPA/SSSI/Ramsar and the effects can be screened out as insignificant at the other sites. At the Swale SPA/SSSI/Ramsar the cumulative PC is 4% of the critical level and based on the cumulative PC alone the impact is potentially significant; however, when the AC is added to the PCs, the cumulative PEC is only 6% of the critical level of 20 μg.m-3 and the impacts can be screened out as insignificant.

Annual-mean NH3

The maximum annual-mean NH3 cumulative PC only exceeds 1% of the critical level at the Swale SPA/SSSI/Ramsar and the effects can be screened out as insignificant at the other sites. At the Swale SPA/SSSI/Ramsar the cumulative PC is 14% of the critical level and based on the cumulative PC alone the impact is potentially significant; however, when the AC is added to the PCs, the cumulative PEC is only 43% of the critical level of 3 μg.m-3 and the impacts can be screened out as insignificant.

Nutrient N Deposition

The maximum nitrogen deposition cumulative PC does not exceed 1% of the critical load for a number of interest features and the effects can be screened out as insignificant. Where the cumulative PC exceeds 1% of the critical load, the impact is potentially significant; however if the cumulative PEC is less than the CL, the impacts can be screened out as insignificant. For the following interest features, the cumulative PC exceeds 1% of the CL and the cumulative PEC exceeds the CL and the impacts are potentially significant. The results have been passed to the projects’ ecologist to assess the effects in Chapter 11.

JAR10341 March 2019 | Rev0 rpsgroup.com/uk

Table 5.4.11 Predicted Nutrient N Deposition at Designated Sites Garden Kemsley of Cumul Reserve Cumu AC Propose K4 CHP Kemsley England Cumulativ Cumul ative CL WKN PC Power Plant lative Designate (kgN.h d K3 PC PC AD Energy e PC ative PEC Interest Feature PC PEC/ d Site (kgN.ha- a-1.yr- (kgN.ha- (EN010090 (SW/11/1 Facility (kgN.ha- PC/CL (kgN.ha- (18/500393/ (kgN.h CL 1.yr-1) 1) 1.yr-1) (18/501923 291) (15/5003 1.yr-1) (%) 1.yr-1) FULL) a-1.yr- (%) /ADJ)) 48/COU 1) NTY)

The Swale Eurasian reed 15 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 32 19.0 127 SPA/Elmle warbler y NNR/ Milton Reed bunting 15 14.2 0.54 0.36 0.1 0.0142 1.92 1.9 4.8 32 19.0 127 Creek LWS

Common tern 8 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 4 13.5 169

Medway Little tern 8 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 4 13.5 169 Estuary and Marshes Hen harrier 10 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 3 13.5 135 SPA

Merlin 10 13.2 0.05 0.05 0.01 0.0005 - 0.19 0.3 3 13.5 135

The Swale Shingle & sea cliff Ramsar/SS (dunes, shingle & 10 14.2 0.54 0.36 0.1 0.0174 1.92 1.87 4.8 48 4.8 190 SI machair)

Medway Estuary Shingle & sea cliff and (dunes, shingle & 10 13.2 0.05 0.05 0.01 0.0007 - 0.19 0.3 3 0.3 135 Marshes machair) Ramsar

JAR10341 March 2019 | Rev0

Acid Deposition

The maximum acid deposition cumulative PC does not exceed 1% of the critical load at Queendown Warren SAC and the impacts can be screened out as insignificant.

Cumulative Impacts at Sensitive Receptors The above assessment does not consider the impacts of cumulative traffic as the areas of maximum impact will be different for stack and traffic emissions. Traffic emissions have been modelled at a selection of discrete receptor points at the closest point of the habitat site to a road adjacent to roads affected by the WKN and K3 proposed development. Only the Swale SPA/SSSI/Ramsar and the Medway Estuary and Marshes SPA/Ramsar are within 200 m of a road affected by the WKN and K3 proposed development.

The A249 passes through the Medway Estuary and Marshes SPA/Ramsar so receptors were selected at the roadside.

Cumulative traffic data for the WKN and K3 Proposed Development in the opening year of WKN, 2024 was modelled. The PC from the WKN and K3 stack emissions at each of the sensitive receptors was added to the road contribution to give a ‘WKN + K3’ PC that considers both stack and traffic emissions. To calculate the cumulative PEC, the maximum PCs for the developments in Table 5.4.5 were added to the highest AC for each habitat site and the WKN + K3 PC. These were compared with the lowest CL for each habitat site. The results are presented in Table 5.5.13 and 5.5.14.

JAR10341 March 2019 | Rev0 Table 5.4.13 Cumulative NOx Predicted Environmental Concentrations – Sensitive Receptors WKN + WKN + K3 K3 Propos Propo ed sed Develop Develo ment + pment Kemsley K4 WKN + K3 Kemsley Reserve Power Garden of England Other + CHP PC Cumulative Cumulative PC (stack AD Plant PC Energy Facility Habitat Site cumulat Other (EN010090 PEC (µg.m- PEC as % emissions) (SW/11/129 (18/500393/FU (15/500348/COUNTY ive cumul (18/501923/A 3) of CL (µg.m-3) 1) LL) ) develop ative DJ)) ments develo Road pment Contrib s PC ution as % (µg.m-3) of CL The Swale 3.23 0.75 13 0.80 1.69 2.23 1.33 22.33 74 SPA/SSSI/Ramsar Medway Estuary and Marshes 1.03 0.35 5 0.10 0.07 0.00 0.11 26.07 87 SPA/Ramsar *Critical level is 30 µg.m-3

Table 5.4.14 Cumulative N Deposition Predicted Process Contributions – Sensitive Receptors WKN + K3 WKN + K3 Garden of PC as % of Kemsley K4 Reserve PC (Traffic England Cumulative CL (Traffic CHP PC Power Plant Cumulative and Stack Minimu Kemsley AD Energy PEC Habitat Site and Stack (EN010090 PC PEC as % of Emissions) m CL (SW/11/1291) Facility (kgN.ha-1.yr- Emissions) (18/501923/A (18/500393/F CL (kgN.ha-1.yr- (15/500348/C 1) (kgN.ha-1.yr- DJ)) ULL) 1) OUNTY) 1) The Swale 0.40 15 3 0.1 0.0174 1.92 1.87 18.51 123 SPA/SSSI/Ramsar Medway Estuary and 0.14 8 2 0.01 0.0007 - 0.19 13.55 169 Marshes SPA/Ramsar

JAR10341 March 2019 | Rev0 For NOx, the cumulative PC as % of the CL exceeds 1% but, the PEC is less than the CL. On that basis, the cumulative effects are considered insignificant.

For N deposition the cumulative PC as % of the CL exceed 1% and the PEC is greater than CL and the impacts are potentially significant. The results have been passed to the projects’ ecologist to assess the effects.

The cumulative PECs presented in Tables 5.4.13 and 5.4.14 can be considered highly conservative as the PCs from the other developments are the maximum impacts across a grid and are unlikely to occur at the same location as the maximum road contribution.

1 Air Pollution Information Systems, www.apis.ac.uk

2 Approaches to modelling local nitrogen deposition and concentrations in the context of Natura 2000 - Topic 4

3 Air emissions risk assessment for your environmental permit

4 Data downloaded from APIS December 2017

JAR10341 March 2019 | Rev0 rpsgroup.com/uk

Document 3.1 – ES Volume 2

APPENDIX 5.6: Air Quality – Odour Assessment Methodology

Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy Facility DCO

September 2019 -Submission Version PINS ref: EN010083

Appendix 5.6: Qualitative Odour Impact Assessment Methodology

Risk Assessment Methodology 1. The qualitative risk-ranking assessment of the odour impact of emissions from the proposed development site has been carried out using the method in the IAQM Guidance Appendix 1 (IAQM, 2014b) which provides examples of risk factors for odour source potential, pathway effectiveness and receptor sensitivity (set out in Table C.1).

Table C.1 IAQM Examples of Risk Factors for Odour Source, Pathway and Receptor

Source Odour Potential Pathway Effectiveness Receptor

Factors affecting the source odour Factors affecting the odour flux to For the sensitivity of people to potential include: the receptor are: odour, the IAQM recommends that the air quality practitioner • the magnitude of the odour • distance from source to uses professional judgement to release (taking into account receptor the frequency identify where on the spectrum odour-control measures) (%) of winds from the between high and low sensitivity source to receptor (or, • how inherently odorous the a receptor lies, taking into qualitatively, the direction compounds are account the following general of receptors from source principles: • the unpleasantness of the odour with respect to prevailing wind) • the effectiveness of any mitigation/control in reducing flux to the receptor • the effectiveness of dispersion/ dilution in reducing the odour flux to the receptor • topography and terrain

Large Source Odour Potential Highly Effective Pathway for High Sensitivity Receptor Magnitude – Larger Permitted processes Odour Flux to Receptor - surrounding land where: – of odorous nature or large STWs; Distance receptor is adjacent to • users` can reasonably materials usage hundreds of thousands the source/site; distance well expect enjoyment of a 3 of tonnes/m per year; area sources of below any official set-back high level of amenity; 2 a thousands of m . distances . and – The compounds involved are very Direction high frequency (%) of • the people would odorous (e.g. mercaptans), having very winds from source to receptor (or, reasonably be low Odour Detection Thresholds (ODTs) qualitatively, receptors downwind expected to be present where known. of source with respect to here continuously, or at Unpleasantness – processes classed as prevailing wind). least regularly for “Most offensive” in H4; or (where Effectiveness of dispersion/dilution extended periods, as known) compounds/odours having - open processes with low-level part of the normal unpleasant (-2) to very unpleasant (-4) releases, e.g. lagoons, uncovered pattern of use of the hedonic score. effluent treatment plant, landfilling land. of putrescible wastes. Mitigation/control – open air operation Examples may include with no containment, reliance solely on residential dwellings, hospitals, good management techniques and best schools/education and practice. tourist/cultural.

Medium Source Odour Potential Moderately Effective Pathway Medium Sensitivity Receptor Magnitude – smaller Permitted processes for Odour Flux to Receptor – surrounding land where: Source Odour Potential Pathway Effectiveness Receptor or small Sewage Treatment Works Distance – receptor is local to the • users’ would expect to (STWs); materials usage thousands of source. enjoy a reasonable tonnes/m3 per year; area sources of level of amenity, but Where mitigation relies on hundreds of m2. wouldn’t reasonably dispersion/dilution – releases are expect to enjoy the The compounds involved are moderately elevated, but compromised by odorous. same level of amenity building effects. as in their home; or Unpleasantness – processes classed in • H4 as “Moderately offensive”; or (where people wouldn’t known) odours having neutral (0) to reasonably be unpleasant (-2) hedonic score. expected to be present here continuously or Mitigation/control – some mitigation regularly for extended measures in place, but significant periods as part of the residual odour remains. normal pattern of use of the land. Examples may include places of work, commercial/retail premises and playing/recreation fields.

Small Source Odour Potential Ineffective Pathway for Odour Low Sensitivity Receptor Magnitude – falls below Part B threshold; Flux to Receptor – surrounding land where: materials usage hundreds of tonnes/m3 Distance – receptor is remote from • the enjoyment of 2 the source; distance exceeds any per year; area sources of tens m . amenity would not The compounds involved are only mildly official set-back distances. reasonably be odorous, having relatively high ODTs Direction – low frequency (%) of expected; or where known. winds from source to receptor (or, • there is transient Unpleasantness – processes classed as qualitatively, receptors upwind of exposure, where the source with respect to prevailing “Less offensive” in H4; or (where people would wind). known) compounds/odours having reasonably be neutral (0) to very pleasant (+4) hedonic Where mitigation relies on expected to be present score. dispersion/ dilution – releases are only for limited periods from high level (e.g. stacks, or roof of time as part of the Mitigation/control – effective, tangible vents > 3 m above ridge height) normal pattern of use mitigation measures in place (e.g. BAT, and are not compromised by of the land. BPM) leading to little or no residual surrounding buildings odour. Examples may include industrial, farms, footpaths and roads. Notes: a Minimum setback distances may be defined for some odorous activities

Source 2. The first step of this qualitative assessment is to estimate the odour-generating potential of the site activities, termed the “Source Odour Potential”. This takes into account three factors:

i. The scale (magnitude) of the release from the odour source, taking into account the effectiveness of any odour control or mitigation measures that are already in place. This involves judging the relative size of the release rate after mitigation and taking account of any pattern of release (e.g. intermittency). The assumption has been made, as required by the NPPF, that the pollution-control regimes applying to these sites will operate effectively and that the appropriate BAT standards of odour control will be enforced. ii. How inherently odorous the emission is. In some cases it may be known whether the release has a low, medium or high odour detection threshold (ODT); this is the concentration at which an odour becomes detectable to the human nose. In most instances the odours released by a source will be a complex mixture of compounds and the detectability will not be known. However, for some industrial processes the odour will be due to one or a small number of known compounds and the detection thresholds will be a good indication of whether the release is highly odorous or mildly odorous.

iii. The relative pleasantness/unpleasantness* of the odour. Lists of relative pleasantness of different substances are given in the Environment Agency guidance H4 Odour Management (Environment Agency, 2011)

3. Using the example risk ranking in Table C.2, the Source Odour Potential can be categorised as small, medium or large.

Table C.2 H4 Offensiveness of Odour Emission Sources

Offensiveness Odour Emission Sources

Processes involving decaying animal or fish remains Most Offensive Processes involving septic effluent or sludge Biological landfill odours

Intensive livestock rearing Fat frying (food processing) Moderately Offensive Sugar beet processing Well aerated green waste composting

Brewery Less Offensive Confectionary Coffee

Pathway Effectiveness 4. Next, the effectiveness of the pollutant pathway as the transport mechanism for odour through the air to the receptor, versus the dilution/dispersion in the atmosphere, needs to be estimated. Anything that increases dilution and dispersion of the odorous pollutant plume as it travels from source (e.g. processes and plant) to receptor will reduce the concentration at the receptor, and hence reduce exposure. Important factors to consider here are:

i. The distance of sensitive receptors from the odour source.

* This can be measured in the laboratory as the hedonic tone, and when measured by the standard method and expressed on a standard nine-point scale it is termed the hedonic score. ii. Whether these receptors are downwind (with respect to the predominant prevailing wind direction). Odour episodes often tend to occur during stable atmospheric conditions with low wind speed, which gives poor dispersion and dilution; receptors close to the source in all directions around it can be affected under these conditions. When conditions are not calm, it will be the downwind receptors that are affected. Overall therefore, receptors that are downwind with respect to the prevailing wind direction tend to be at higher risk of odour impact.

iii. The effectiveness of the point of release in promoting good dispersion, e.g. releasing the emissions from a high stack will - all other things being equal - increase the pathway, dilution and dispersion.

iv. The topography and terrain between the source and the receptor. The presence of topographical features such as hills and valleys, or urban terrain features such as buildings can affect air flow and therefore increase, or inhibit dispersion and dilution.

5. Using the example risk ranking in Table C.3, the pollutant pathway from source to receptor can be categorised as ineffective, moderately effective, or highly effective.

Odour Exposure Risk 6. In the third step, the estimates of Source Odour Potential and the Pathway Effectiveness are considered together to predict the risk of odour exposure (impact) at the receptor location, as shown by the example matrix in Table C.3.

Table C.3 Risk of Odour Exposure (Impact) at the Specific Receptor Location

Source Odour Potential

Small Medium Large

Highly effective Low Risk Medium Risk High Risk

Moderately Pathway Effectiveness Negligible Risk Low Risk Medium Risk effective

Ineffective Negligible Risk Negligible Risk Low Risk

Assessment of the Effect of Odour Exposure 7. The next step is to estimate the effect of that odour impact on the exposed receptor, taking into account its sensitivity, as shown by the example matrix in Table C.4. The odour effects may range from negligible, through slight adverse and moderate adverse, up to substantial adverse.

Table C.4 Likely Magnitude of Odour Effect at the Specific Receptor Location

Receptor Sensitivity Risk of Odour Exposure Low Medium High Moderate Adverse High Slight Adverse Effect Substantial Adverse Effect Effect

Medium Negligible Effect Slight Adverse Effect Moderate Adverse Effect

Low Negligible Effect Negligible Effect Slight Adverse Effect

Negligible Negligible Effect Negligible Effect Negligible Effect

8. This procedure results in a prediction of the likely odour effect at each sensitive receptor. The next step is to estimate the overall odour effect on the surrounding area, taking into account the different magnitude of effects at different receptors, and the number of receptors that experience these different effects*. This requires the competent and suitably experienced Air Quality Practitioner to apply professional judgement.

9. This procedure results in a prediction of the likely odour effect at each sensitive receptor. The next step is to estimate the overall odour effect on the surrounding area, taking into account the different magnitude of effects at different receptors, and the number of receptors that experience these different effects*. This requires the competent and suitably experienced Air Quality Practitioner to apply professional judgement.

* Unless there is only a small number of local receptors, then a representative selection of receptors will have been used in the assessment. This final stage of considering the overall effect needs to take into account how many receptors these selected ones represent.

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6 Greenhouse Gases and Climate Change

6.1 Introduction

This chapter assesses the likely significant effects resulting from the K3 and WKN Proposed Developments as a consequence of greenhouse gas (GHG) emissions and the resultant impact on climate change.

It is supported by Appendices 6.1, 6.2 and 6.3 containing details of the GHG emissions calculations.

GHG emissions are normally expressed as carbon dioxide equivalents, explained in the methodology section below, and are therefore often referred to as ‘carbon’ as a shorthand (e.g. when speaking of ‘low-carbon power’ or ‘carbon reduction targets’).

With regard to potential climate change inter-relationships with other assessments reported in this ES, climate change impacts on flood risk and coastal change affecting the Proposed Developments are assessed in Chapter: 10 Water Environment. In the judgement of the authors of Chapter 11: Ecology and Chapter 12: Landscape and Visual Effects, there is not considered to be any relevant influence of climate change on the status of ecological or landscape receptors impacted by the development.

6.2 Regulatory and Policy Framework

National Climate Change and Waste Legislation and Policy

Climate Change Act, 2008

The Climate Change Act 2008 as amended by the 2050 Target Amendment Order 2019 [Ref. 6.1] commits the UK government to reducing greenhouse gas emissions by at least 100% of 1990 levels by 2050 (a net zero carbon target for the UK), and created a framework for setting a series of interim national carbon budgets and plans for national adaptation to climate risks.

At present the Third, Fourth and Fifth Carbon Budgets, set through The Carbon Budget Orders 2009, 2011 and 2016, are 2.54 GtCO2e for 2018-2022, 1.95 GtCO2e for 2023-2037 and 1.73 GtCO2e for 2028-2032.

The Climate Change Act also created the Committee on Climate Change to give advice on carbon budgets and report on progress. The Committee through its Adaptation Sub-Committee also gives advice on climate change risks and adaptation. Its advice regarding carbon and climate policy relevant to the Proposed Development is summarised below.

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Carbon Plan, 2011

The 2011 Carbon Plan [Ref. 6.2] is the UK’s national strategy under the Climate Change Act for delivering emissions reductions through to the Fourth Carbon Budget period (2023-27) and preparing for further reductions to 2050.

It was expected to be updated or replaced by a national ‘Emissions Reduction Plan’ that the former coalition government committed to publish in 2016, but that has been delayed indefinitely. Due to the age of the Carbon Plan, certain policy expectations have been overtaken by subsequent policy decisions: in particular, the expected government funding for deployment of carbon capture and storage (CCS) technology lapsed following the failure of the second CCS competition [Ref. 6.3], though CCS support has been revived in the UK CCUS Deployment Pathway action plan [Ref 6.4], albeit with limited funding available.

The Carbon Plan chapter on Waste and Resource Efficiency (pages 93-99) describes a three-pronged strategy, of:

• preventing waste arising;

• reducing methane emissions from landfill; and

• efficient energy recovery from residual waste.

In addition to referencing the GHG emission benefits of reducing the amount of waste landfilled in general, the Carbon Plan states in paragraph 2.223 that “The Government’s aim is to get the most energy out of waste, not the most waste into energy recovery” and in paragraph 2.224 that “Efficient energy recovery from waste prevents some of the negative greenhouse gas impacts of waste in landfill and helps to offset fossil fuel power generation.”

In Box 7 on page 41, the Carbon Plan lists CHP using fuels including waste among technology options to supply “low carbon heat” and in paragraphs 2.130 and 2.132, describes energy from waste as a sustainable biomass source and low carbon heat source for large-scale CHP opportunities.

Waste Management Plan for England, 2013

The Waste Management Plan 2013 [Ref. 6.5] states in its future-looking evaluation on page 34 that Defra “prioritis[es] efforts to manage waste in line with the waste hierarchy and reduce the carbon impact of waste”.

On page 13 it states that “The Government supports efficient energy recovery from residual waste – of materials which cannot be reused or recycled – to deliver environmental benefits, reduce carbon impact and provide economic opportunities.”

Clean Growth Strategy, 2017

The 2017 Clean Growth Strategy for the UK [Ref. 6.6] notes the significant progress made in decreasing GHG emissions from waste going to landfill and adopts goals of being a ‘zero avoidable waste economy’ by 2050 and diverting all

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food waste from landfill by 2030. The Strategy does not discuss energy from waste and effects on GHG emissions in detail, but does have a goal for the National Infrastructure Commission to “work with the waste sector to ensure that different waste materials going into energy recovery processes are treated in the best possible way” (page 111).

National Infrastructure Assessment, 2018

Although not adopted national policy, the advice of the National Infrastructure Commission (NIC, an executive agency of the Treasury) given in the National Infrastructure Assessment [Ref. 6.7] is also considered relevant.

While noting the benefits of EfW for diverting waste from landfill, the National Infrastructure Assessment recommends that more use of alternative treatment for food waste and plastic in particular is encouraged to reduce GHG emissions. On page 34 it states:

“The successful delivery of a low cost, low carbon energy and waste system requires… encouraging more recycling, and less waste incineration.”

And on pages 45-46:

“Incinerating less, recycling more

Energy from waste plants (incinerators) facilitated the move away from landfill, and make sense when the alternative is energy from fossil fuels. They incinerate ‘black bag’ waste and other wastes that cannot be recycled, producing electricity and providing heat where there is a source of demand nearby. However, lower cost, lower carbon options exist for some types of waste, in particular food waste and plastics.”

Advice of the Committee on Climate Change

Although not itself setting government policy, the Committee on Climate Change’s statutory role to advise government under the Climate Change Act 2008 means that its recommendations or identification of policy gaps are relevant to consider in this assessment. In its 2015 advice [Ref. 6.8] on setting the Fifth Carbon Budget and on sectoral scenarios [Ref. 6.9] for achieving the budget, the Committee considered carbon reduction pathways and actions for the waste management and power generation sectors, both relevant to the K3 and WKN Proposed Developments.

Chapter 7 of the sectoral scenarios report concerns waste management. It describes the progress made to date in reducing GHG emissions from landfill and states that further reducing landfill emissions is the main focus of this sectoral scenario for the future. On page 201, “incineration with energy recovery” is listed among the technology options for landfill waste diversion.

Chapter 2 of the sectoral scenarios report concerns decarbonising power generation. Decarbonisation of electricity supply, to 50-100 gCO2/kWh by 2030

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from around 450 gCO2/kWh1, is crucial for many other sectors in achieving the UK carbon budget, including industry. Again, the importance of CCS deployment for fossil-fuelled power generation in the 2020s onwards is emphasised.

The Committee’s 2017 and 2018 reports to Parliament identify significant policy gaps for meeting carbon budgets [Refs. 6.10, 6.11]. On page 8 in the 2017 report, the Committee stated that:

“New policies are needed across the economy. By 2030, current plans would at best deliver around half of the required reduction in emissions, 100-170 MtCO2e per year short of what is required by the carbon budgets.”

The 2018 report re-emphasises the call for urgent action, noting that aside from the power sector, national emissions reductions have largely stalled and that the fourth carbon budget will be challenging to meet. It calls for a new national strategy for CCS deployment for power and industry, for uptake of low-carbon heat and energy efficiency measures in industry, and for banning biodegradable waste from landfill by 2025 at the latest.

The Committee’s 2019 report supporting the recommendation (now adopted) that the UK sets a net zero target for 2050 [Ref 6.12] indicates that electricity generation will need to be almost fully decarbonised by 2050 and that industry will require greater deployment of CCUS, use of hydrogen, and electrification. With regard to waste management it suggests that no biodegradable waste should be landfilled after 2025 and that recycling rates of 70% should be targeted, further reducing residual waste.

The UK’s ratification of the Paris Agreement [Ref. 6.13] will in the advice of the Committee require more ambitious UK carbon emission reductions than had been legislated for in the Climate Change Act 2008, particularly beyond 2050. Pending further changes in emissions reduction pledges by other EU member states, the Committee had not initially recommended that the Fifth Carbon Budget should be altered [Refs. 6.14, 6.15], but this is now likely to change with the recent adoption of the UK's net zero target for 2050 when further carbon budget advice is published.

Concerning the implications of Brexit for UK climate change policy, the Committee notes [Ref. 6.16] that this does not affect the existence of the UK’s domestically- legislated climate goals for 2050. In summary, the Committee indicates that domestic policies to achieve the equivalent effects on GHG reductions as lost EU- level policies will be required, and highlights again the existing policy gap for achieving carbon reductions required by the Fifth Carbon Budget.

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Planning Policies

National Policy Statement for Energy, EN-1

The Overarching National Policy Statement for Energy (EN-1) [Ref. 6.17] states that while “the UK economy is reliant on fossil fuels, and they are likely to play a significant role for some time to come… the UK needs to wean itself off such a high-carbon energy mix: to reduce greenhouse gas emissions…” (paragraphs 2.2.5 and 2.2.6).

Of note also is the statement at paragraph 2.2.4 that:

“Not all aspects of Government energy and climate change policy will be relevant to IPC decisions or planning decisions by local authorities, and the planning system is only one of a number of vehicles that helps to deliver Government energy and climate change policy. The role of the planning system is to provide a framework which permits the construction of whatever Government – and players in the market responding to rules, incentives or signals from Government – have identified as the types of infrastructure we need in the places where it is acceptable in planning terms.”

The NPS discusses the challenges of balancing security and stability of energy supply with need for low-carbon/renewable generation technologies, and the benefits of a diverse energy supply mix (section 3.6). In paragraph 3.4.3 it notes that the energy produced in EfW facilities from the biomass fraction of residual waste is regarded as renewable.

Section 4.6 of NPS EN-1 supports CHP for thermal generating stations on grounds including the efficiency of displacing conventional fossil-fuelled separate heat and electricity generation (paragraph 4.6.8), with consequent potential for GHG emission reductions. Section 4.7 requires applicants to demonstrate readiness for future use of CCS.

Paragraph 5.2 states that:

“CO2 emissions are a significant adverse impact from some types of energy infrastructure which cannot be totally avoided (even with full deployment of CCS technology). However, given the characteristics of these and other technologies, as noted in Part 3 of this NPS, and the range of non-planning policies aimed at decarbonising electricity generation such as EU ETS (see Section 2.2 above), Government has determined that CO2 emissions are not reasons to prohibit the consenting of projects which use these technologies or to impose more restrictions on them in the planning policy framework than are set out in the energy NPSs (e.g. the CCR and, for coal, CCS requirements). Any ES on air emissions will include an assessment of CO2 emissions, but the policies set out in Section 2, including the EU ETS, apply to these emissions. The IPC does not, therefore need to assess individual applications in terms of carbon emissions against carbon budgets and this section does not address CO2 emissions or any Emissions Performance Standard that may apply to plant.”

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However, it should be noted that the EU ETS does not apply to waste combustion installations and it does not appear that this would change with the introduction of carbon pricing following Brexit, with paragraph 3.51 of the Budget 2018 [Ref. 6.18] stating that in the event of departure from the EU ETS, a new carbon emissions tax introduced would apply only to installations currently participating in the ETS.

National Planning Policy Framework (NPPF)

With regard to climate change, the core planning principle of the NPPF [Ref. 6.19] is that the planning system should:

“…support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure” (paragraph 148).

Under paragraph 154, applicants for energy development are not required to demonstrate the overall need for low-carbon energy. ‘Low-carbon’ technologies are defined in the NPPF at page 70 as “…those that can help reduce emissions (compared to conventional use of fossil fuels).”

Kent County Council Minerals and Waste Local Plan 2013-30, 2016

The Kent Minerals and Waste Local Plan 2013-30, adopted in July 2016 [Ref. 6.20], states in its spatial vision at paragraph 3.0.2 that it aims to drive waste up the Waste Hierarchy and “ensure that requirements such as a Low Carbon Economy (LCE) and climate change issues are incorporated into new developments for minerals and waste development in Kent”. Point 1 of the Spatial Vision (page 32) is for waste developments to “make a positive and sustainable contribution to the Kent area and assist with progression towards a low carbon economy.”

The Local Plan’s second strategic objective, on page 36, is to:

“Ensure minerals and waste developments contribute towards the minimisation of, and adaptation to, the effects of climate change. This includes helping to shape places to secure radical reductions in greenhouse gas emissions and supporting the delivery of renewable and low carbon energy and associated infrastructure.”

Policy DM 1: Sustainable Design states that:

“Proposals for minerals and waste development will be required to demonstrate that they have been designed to:

1. minimise greenhouse gas emissions and other emissions

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2. minimise energy and water consumption and incorporate measures for water recycling and renewable energy technology and design in new facilities where possible 3. maximise the re-use or recycling of materials…”

The explanatory notes for policy DM 12: Cumulative Impact indicate that climate change should be in the evaluation of significant cumulative effects on the environment (see paragraph 7.10.3).

Swale Borough Council’s Development Plan, 2017

Swale Borough Council Local Plan, adopted on 26th July 2017 [Ref. 6.21], states in paragraph 4.1.48 under the subheading of “Meeting the challenge of climate change, flooding and coastal change” in section 4 that:

“Our strategy for climate change is adaptation and mitigation – resilient to future challenges and supportive of new opportunities. Businesses able to increase jobs in low carbon sectors will be encouraged and those making sustainable changes to adapt will be supported. We will also encourage existing homes and businesses to improve their energy and waste efficiencies.”

Paragraph 4.1.50 indicates that:

“We also need to move beyond adaptation to the impacts of climate change, reducing greenhouse gas emissions where we can. Here, the strategy has three strands:

….

3. Encouraging the use of renewables and energy efficiency improvements (inc. micro-renewable energy and free-standing projects), identifying the potential for decentralised, renewable or low carbon energy supplies and for co-locating heat customers and suppliers.”

Local Plan Core Objective 1 is to “adapt to climate change with innovation, reduced use of resources, managed risk to our communities and opportunities for biodiversity to thrive.”

Policy ST1 item 10 is to:

“Meet the challenge of climate change, flooding and coastal change through:

a. promotion of sustainable design and construction, the expansion of renewable energy, the efficient use of natural resources and the management of emissions;

b. the management and expansion of green infrastructure; and

c. applying planning policies to manage flood risk and coastal change.”

Policy CP1 states that:

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“Development proposals will, as appropriate:

…

Create resilience in existing businesses to forecast changes in flood risk, climate change and natural processes or lead to an expansion of businesses in the low carbon sectors.”

Policy CP4 states that:

“Development proposals will, as appropriate:

…

Maximise opportunities for including sustainable design and construction techniques including the use of recycled and recyclable materials, sustainable drainage systems, carbon reduction and minimising waste.”

Policy DM19 states that:

“Development proposals will include measures to address and adapt to climate change in accordance with national planning policy and guidance and, where appropriate, will incorporate the following:

a. Use of materials and construction techniques which increase energy efficiency and thermal performance, and reduce carbon emissions in new development over the long term unless considerations in respect of the conservation of heritage assets indicate otherwise;

b. Promotion of waste reduction, re-use, recycling and composting, where appropriate, during both construction and the lifetime of the development;

c. Recognition that retaining and upgrading existing structures may be more sustainable than building new whilst making the most of opportunities to improve water and energy efficiency in the existing stock;

…

2. Development proposals should, where appropriate, be located, oriented and designed to take advantage of opportunities for decentralised, low and zero carbon energy, including passive solar design, and, connect to existing or planned decentralised heat and/or power schemes.

…”

And Policy DM20 is that “planning permission will be granted for the development of renewable and low carbon energy sources” subject to the development being judged acceptable through a number of environmental, planning and social criteria listed in that policy.

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6.3 Methodology

Scoping and Consultation

The proposed scope and approach to this assessment were set out in sections 6.3 and 7.3 of the Scoping Report submitted as part of the formal Scoping Opinion request to the Planning Inspectorate (PINS) (Appendix 3.1). Further details of the formal scoping undertaken with PINS and consultees, including copies of the Scoping Report and Scoping Opinion, are given in Chapter 3 and its appendices.

On pages 19-20 (Section 4.3) of the Scoping Opinion, PINS provides comments on the proposed scope of assessment with regard to (a) climate change risks/vulnerability, adaptation and resilience and (b) greenhouse gas emissions for the K3 and WKN Proposed Developments.

Subsequent advice from PINS in June 2019, explained in Section 3.2 of Chapter 3, has led to the DCO application seeking permission for construction and operation of K3 as a whole (the “K3 Proposed Development”, i.e. a 75 MW generating station with total annual waste throughput of 657,000 tpa). The scope of assessment for the EIA has been extended where applicable to include assessment of the construction, operation and decommissioning effects of the K3 Proposed Development. However, the practical effect of the K3 Proposed Development remains an increase of generating capacity by 25 MW2 and throughput by 107,000 tpa beyond K3 as consented (see Chapter 2 for further details). This is reflected in the K3 sub-sections of the assessment section of this ES chapter, and the Scoping Opinion responses have been interpreted with regard to both the K3 Proposed Development and the practical effect of the K3 Proposed Development.

GHG emissions

In the PINS Scoping Opinion, response ID 4.3.1 agrees that assessment of GHG emissions during construction can be scoped out for the K3 Proposed Development. Responses 4.3.1, 4.3.3 and 4.3.4 indicate that GHG emissions during construction of the WKN Proposed Development, operation and, where likely to be significant, decommissioning of the K3 and WKN Proposed Developments should be scoped in to the assessment. The impacts of GHG emissions are reported in this chapter.

Climate change risks/vulnerability, adaptation and resilience

Response ID 4.3.5 agrees that vulnerability to climate change can be scoped out of the assessment for the WKN Proposed Development save in respect of flood risk, which is assessed in Chapter: 10 Water Environment, and vulnerability of habitats to effects from nitrogen deposition. As set out in Chapter: 11 Ecology, climate change is not considered to significantly affect the vulnerability of habitats.

Response ID 4.3.2 indicates that climate change risks, adaptation and resilience for the K3 Proposed Development should be scoped out of the construction

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assessment but scoped in for operation and, where likely to be significant, decommissioning. This response is difficult to interpret, as it is the opposite position to that taken for the neighbouring WKN Proposed Development . It is unclear how the effect of the K3 Proposed Development application could lead to any greater likelihood of significant climate risks during operation or decommissioning than the WKN Proposed Development, particularly given that the design of the K3 Proposed Development is already consented and the practical effect of the K3 Proposed Development application involves no physical changes to the facility (which is already largely constructed and expected to be ready for operation by the end of 2019).

Given this, response ID 4.3.5 has been interpreted as applying to both the WKN and K3 Proposed Developments and assessment of climate change risks, adaptation and resilience is scoped out of the assessment.

Natural England has commented in paragraph 5 of Annex A of its consultation response to the Scoping Report that “the ES should… identify how the development’s effects on the natural environment will be influenced by climate change…”, in the context of the principles for consideration of climate change effects on biodiversity set out in the England Biodiversity Strategy. Chapter: 11 Ecology has addressed this point.

PINS and several statutory consultees have commented on climate change in the context of flood risk and coastal change. This is assessed in Chapter: 10 Water Environment.

Greenhouse Gas Emission Calculations – Overview

In overview, GHG emissions have been estimated on a life-cycle basis using the waste sector software tool Waste and Resources Assessment Tool for the Environment (WRATE), originally developed for the Environment Agency and now maintained by Golder Associates. This tool allows a comparison of GHG emissions from different waste management scenarios, including models of the operation of energy-from-waste (EfW) facilities (which can be customised with facility-specific parameters such as generation efficiency) and of waste decomposition in landfill.

In addition to CO2 emissions, WRATE reports the emission of other relevant greenhouse gases expressed as CO2-equivalent based on 100-year global warming potential (GWP). This is denoted by CO2e units in emissions factors and calculation results.

Mixed waste typically contains both ‘biogenic’ and ‘fossil’ carbon, both of which are released as CO2 when the waste is incinerated. Biogenic carbon is that in plant-derived material (such as food waste) whereas fossil carbon is that in material derived from fossil fuels, such as plastics. Only fossil carbon is regarded as causing a net increase in atmospheric CO2 concentration, having been released from long-term geological storage. Biogenic carbon was drawn down from the atmosphere by the plants during growth prior to being released again by

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combustion, so over this short cycle does not change the net atmospheric concentration.

Full details of the emissions calculation with data inputs, assumptions and results, are given in the WRATE reports for the practical effect of the K3 Proposed Development and the WKN Proposed Development at Appendix 6.1 and Appendix 6.2 respectively. Appendix 6.3 provides an addendum to Appendix 6.1, calculating total GHG emissions for the K3 Proposed Development.

Establishing Baseline Conditions

The baseline conditions are the business-as-usual scenario for waste management and energy generation that would have occurred in the absence of either the WKN Proposed Development or the K3 Proposed Development (including the practical effect).

The Waste Hierarchy and Fuel Availability Report (application document number 4.6) shows that the current management route for residual waste that would be managed by the K3 and WKN Proposed Developments is either landfill disposal or export as RDF to continental Europe. Landfill has formed the primary baseline scenario in the WRATE assessment. Transport of waste to landfill, the greenhouses gases generated by waste decomposition and the partial capture of gas and use for electricity generation at the landfill are modelled.

As a sensitivity test for the WKN Proposed Development, the WRATE assessment also considers a scenario in which waste were exported to Europe for combustion in a combined heat and power (CHP) EfW facility, as is common for refuse-derived fuel (RDF) produced from residual waste at present (pre-Brexit). Shipping of waste, combustion in the EfW facility, treatment and recovery of residues (fly ash, bottom ash and metals) and the effects of heat and power export are modelled.

The baseline for operation of the K3 Proposed Development for the ‘practical effect’ assessment is its currently consented design, i.e. its waste throughput capacity and energy generation efficiency, which has been established from design information supporting its current planning permission.

The baseline for electricity generation that would be displaced by electricity exported by either facility is assumed in WRATE to be 0.349 tCO2e/MWh (representative of a combined cycle gas turbine [CCGT] power station). The marginal source will change over time, and so for future years in the main scenario, the BEIS projections of the carbon intensity of long-run marginal electricity generation [Ref. 6.22] have also been considered in this chapter.

For the K3 Proposed Development, an emissions factor representative of gas-fired heating is used by WRATE for heat generation displaced by heat supplied by K3 in CHP operation. No baseline scenario for heat generation is required for the K3 Proposed Development ‘practical effect’ assessment, as the resultant modifications would not change its design heat export.

The WKN Proposed Development would not export heat, so there is no displaced baseline heat generation to assess in the main WRATE scenario. In the sensitivity test alternative baseline scenario of waste export to a European CHP (see

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paragraphs 6.3.16 and 6.3.35), again an emissions factor representative of gas- fired heating is used by WRATE for heat generation displaced by the European CHP plant in that scenario.

Significance Criteria

The magnitude of impact on climate change has been quantified as mass of GHG emissions expressed as tCO2e per annum in each case for the K3 Proposed Development and for the WKN Proposed Development.

GHG emissions have a global effect rather than directly affecting any specific local receptor to which a level of sensitivity can be assigned. The global atmospheric mass of the relevant GHGs and consequent warming potential, expressed in CO2-equivalents, has therefore been treated as a single receptor of high sensitivity (given the severe consequences of global climate change). This sensitivity takes into consideration the cumulative effect of all other sources of GHG emissions that contribute to the atmospheric concentration.

Assessment guidance for GHG emissions [Ref. 6.23] indicates that in principle, any GHG emissions may be considered to be significant, and advocates as good practice that GHG emissions should always be reported at an appropriate, proportionate level of detail in an ES. There are however no clear, generally- agreed thresholds or methods for evaluating the significance of GHG effects in EIA, with the guidance suggesting that several possible approaches could be taken.

For this assessment, the total GHG emissions from the operation of the K3 Proposed Development and the WKN Proposed Development have been compared to the baseline in each case in order to evaluate the net change in GHG impact4.

Effects from GHG emissions are described in this chapter as being adverse, neutral/negligible or beneficial based on whether there is predicted to be an increase, little or no net change, or a decrease compared to the baseline, respectively. Adverse or beneficial effects are considered to be significant, taking into account the IEMA guidance and the high sensitivity of the receptor. Neutral/negligible effects are not considered to be significant. It is not considered possible to further differentiate degrees of significance (e.g. slight or major).

Assessment of Effects

Construction

WRATE takes a lifecycle assessment approach to GHG emissions, which includes accounting for emissions associated with materials consumption (embodied carbon) and activity during the construction phase. This is based on a database of representative information for energy-from-waste facilities. The construction-

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stage emissions are then amortised over the operating lifetime of the facility in the WRATE scenario and reported as part of the total annual emissions.

Operation

Direct GHG emissions from operation of the K3 and WKN Proposed Developments are calculated in WRATE based on a model of EfW operation using typical EfW process data that is adjusted with development-specific information such as waste composition, calorific value and energy generation efficiency.

The main emissions sources assessed include:

• direct combustion emissions;

• other process inputs (consumables, parasitic load);

• nitrous oxide emissions from ammonia slip in the air pollution control system;

• management of process outputs (disposal to landfill, re-use or recycling as applicable for bottom ash, fly ash and metals); and

• transport of waste and outputs.

The WRATE assessment assumes 100% uptime, i.e. 8,760 hours of operation per year.

For the K3 Proposed Development, the WRATE analysis has assessed the full 657,000 tpa throughput and 75 MW2 generating capacity.

For the practical effect of the K3 Proposed Development, an increase in waste throughput of 130,000 tonnes per annum (tpa) has been assessed in the WRATE analysis. This is based on design-point data for the consented K3, with 527,000 tpa throughput, increasing to 657,000 tpa throughput with the K3 Proposed Development. K3’s consented throughput is slightly higher at 550,000 tpa, from which the increase to 657,000 tpa would only be 107,000 tpa. However, the 130,000 tpa increase from the K3 design-point throughput rather than consented throughput is considered a more realistic scenario for assessment in the WRATE analysis.

The operational emissions are compared with the applicable baseline scenarios for waste management and energy generation, discussed above, to calculate the net operational emissions total.

Decommissioning

Similarly to construction-stage emissions, decommissioning stage emissions are estimated in WRATE on a lifecycle basis and amortised over the operating lifetime of the facility in the WRATE scenario to be reported as part of the total annual emissions.

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Limitations and Assumptions

The main uncertainties and assumptions concern the baseline scenario to which the K3 and WKN Proposed Developments are compared in order to predict their net impacts. There is a wide variety of options for waste management, which are suited to different waste streams and have varying levels of deployment; however, all leave some fraction of residual waste (from a typical composition) requiring treatment and recovery or disposal. The future baseline scenario for waste management may also be affected by changes in national waste policy.

Although various waste management options exist, a significant fraction of residual waste is still landfilled in the UK or exported as RDF. The national policy drivers to divert waste from landfill to alternatives such as the recovery operations of both the K3 and WKN Proposed Developments are expected to continue, and Brexit could also affect RDF exports [Ref. 6.25]. Both the K3 and WKN Proposed Developments would treat residual waste and the Waste Hierarchy and Fuel Availability Report (application document number 4.6) shows that it is most likely that this waste would otherwise be landfilled or exported to continental Europe as RDF.

The landfill baseline is sensitive to assumptions about landfill management, specifically the ratio of CH4 to CO2, the gas capture rate, utilisation for energy generation, oxidisation of fugitive gas passing through the capping layer, the percentage of decomposable carbon in the waste composition, its decay rate, and sequestration of biogenic carbon. Default assumptions for these factors are used in the GasSim module in WRATE but sequestration of biogenic carbon is excluded.

As sensitivity tests, the WRATE assessment has also considered the following assumptions:

• an alternative indicative baseline scenario for the WKN Proposed Development of waste export to a European EfW CHP facility with a modest combined net efficiency of 34.4%;

• either 45% or 53% biogenic content in the waste composition for the WKN Proposed Development; and

• either 9.5 MJ/kg or 10.5 MJ/kg net calorific value (NCV) of the waste for the K3 Proposed Development.

There is uncertainty about future climate and energy policy and market responses, which affects the likely future carbon intensity of energy supplies. Government projections consistent with current national carbon budget commitments have been considered in addition to the default marginal carbon intensity factor in WRATE.

The calculated emissions performance of the K3 and WKN Proposed Developments is sensitive to the expected waste composition, calorific value, biogenic content and rate of metals recovery from bottom ash. Best estimates drawing from the facility design data, the Applicant’s experience operating other EfW facilities and representative data in WRATE have been applied for these parameters.

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6.4 Baseline Conditions

Table 6.1 shows the baseline GHG emissions from landfill disposal of waste and, as a sensitivity test, from treatment in a hypothetical European EfW CHP facility.

Table 6.2 shows the current baseline GHG emissions from energy generation. There would be no change in heat exported due to the K3 Proposed Development practical effect (compared to its consented operation) and no heat export from the WKN Proposed Development, so heat export is not shown in those cases. All figures are given per annum.

Proposed development Waste amount Net baseline GHG Net baseline GHG (t) emissions – emissions – CHP landfill (tCO2e) EfW (tCO2e) K3 Proposed Development 657,000 196,944 n/a K3 Proposed Development (practical effect) 130,000 38,969 n/a WKN Proposed Development 390,000 116,611 39,708

Table 6.1: Baseline GHG emissions from baseline waste management

Proposed development Energy exported (MWh) Baseline GHG emissions (tCO2e) K3 Proposed Development 541,667 (electricity) 189,042 397,222 (heat) 100,250 K3 Proposed Development (practical effect) 202,989 (electricity) 70,843 WKN Proposed Development 311,111 (electricity) 108,578

Table 6.2: Baseline GHG emissions from baseline energy generation

Sensitive Receptors

The sensitive receptor(s) listed in Table 6.3, below, have the potential to be affected by the K3 and WKN Proposed Developments. The assessment in this chapter has considered the effects listed in the table upon the identified sensitive receptor(s).

Receptor Importance/sensitivity/vulnerability to change Global atmospheric mass of the relevant GHGs and High consequent warming potential, expressed in CO2- equivalents

Table 6.3: Potentially affected sensitive receptors

6.5 Future baseline

The current baseline for waste management (see Section 6.4) is assumed to be representative of the future baseline.

Table 6.4 shows projections of the future baseline carbon intensity of marginal electricity generation over 50 years from 2021 and 2024, the design lifetimes of the K3 and WKN Proposed Developments respectively specified by the Applicant.

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Year Carbon intensity (tCO2e/MWh) 1 2021 0.2582 5 2025 0.2045 10 2030 0.1184 15 2035 0.0761 20 2040 0.0489 25 2045 0.0371 30 2050 0.0252 31-50 2051 onwards 0.0252 Source: BEIS, 2018 [Ref. 6.22]

Table 6.4: Projected carbon intensity of marginal electricity generation (future baseline)

6.6 The K3 Proposed Development Predicted Effects

Explanatory Note

This assessment is of the K3 Proposed Development as a whole, i.e. the full waste throughput and generation capacity. Further details are provided in Section 2.8 of Chapter 2.

Construction Effects

The K3 facility is already well advanced in construction, due for completion in 2019. Nevertheless, construction effects have been assessed. The WRATE analysis addendum reported in Appendix 6.3 indicates that the GHG emissions associated with construction of a typical facility of this capacity, taking into account the embodied carbon in materials used and on-site use of construction plant and energy consumption, is approximately 63 ktCO2e.

Amortised over the expected 30-year operating lifetime of the K3 Proposed Development, this would be a very minor contribution to lifecycle impacts of the facility as a whole, equivalent to <1% of process emissions and substantially outweighed by the beneficial effect predicted due to GHG emission reductions caused by the completed development (see following section).

Construction stage effects (which have largely already been incurred) are therefore considered negligible to the overall GHG emission effects of the K3 Proposed development and not significant.

Completed Development Effects

The WRATE analysis reported in Appendix 6.1 read together with the addendum reported in Appendix 6.3 indicates that the K3 Proposed Development as a whole would provide a net carbon benefit (emissions reduction) of approximately -232.1 ktCO2e/annum compared to the baseline of landfill disposal of the 657,000 tpa of waste and baseline heat and electricity generation.

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The direct process emissions from waste combustion and transport would be 5, approximately +255 ktCO2e/annum while the electricity exported would displace approximately -189 ktCO2e/annum and the heat exported would displace approximately -100 ktCO2e/annum. The net total avoided landfill burden would 7 be approximately -197 ktCO2e/annum .

As a sensitivity test, the WRATE analysis has also considered a scenario with a higher waste NCV of 10.5 MJ/kg while adjusting the assumed composition to keep the 45% biogenic content constant, which is consistent with the main scenario assumption for the WKN Proposed Development. In that scenario, the net benefit of the K3 Proposed Development as a whole would increase to -244.2 ktCO2e/annum due to the greater amount of electricity generated and exported from the higher-CV waste.

Sequestration of the potential fraction of biogenic carbon not decaying in landfill is not a parameter that forms part of the net baseline emissions in the WRATE analysis, as this has fairly high uncertainty. Significant sequestration of biogenic carbon in the landfill baseline would decrease the baseline landfill GHG emissions and hence decrease the net GHG emissions reduction attributable to the K3 Proposed Development from avoided landfill. However, in another area of uncertainty for the baseline, the lifetime landfill gas capture rate, WRATE makes a relatively optimistic assumption of 75%. A lower gas capture rate in practice would lead to higher GHG emissions in the landfill baseline, increasing the net GHG emissions reduction attributable to the K3 Proposed Development. To a degree these two points may balance out, though this cannot be stated definitively either way as the precise parameters of waste decay in landfill and management of this over a lengthy gas-generating lifetime are difficult to predict for a hypothetical baseline scenario.

In summary, considering the magnitude of GHG emission reductions predicted in the WRATE analysis due to the K3 Proposed Development, and the policy support for CHP and diversion of waste from landfill, the K3 Proposed Development is considered to have a beneficial effect that is significant, applying the definition in paragraph 6.3.25.

ther factors modelled such as the consumption of process consumables (other than the waste fuel) and management of the bottom ash (including metals recycling) make relatively small positive and negative contributions to the emissions that tend to roughly balance out. The overall net process emissions total is 254,173 ktCO2e/annum. 6 of fossil carbon. Short-cycle biogenic carbon, having a net neutral effect on atmospheric concentration, would be an additional 78,248 ktCO2e/annum. 7 excluding biogenic carbon sequestration

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Decommissioning Effects

The WRATE analysis indicates that decommissioning would make a very minor contribution to lifecycle impacts, equivalent to <0.1% of process emissions, so this is considered negligible and not significant. Furthermore:

• it is possible that foundations and structures for the K3 Proposed Development could be re-used, incurring no additional GHG emissions attributable to it;

• it is likely that much of the K3 Proposed Development’s structure and energy generation components have been constructed of steel and other metals with good potential for recycling, in which case the benefits of recycling are attributed to the new material user in BEIS GHG reporting guidance (i.e. not attributed to the K3 Proposed Development); and

• if disposed of and not recycled, the K3 Proposed Development’s construction materials are likely to be mainly inert waste (e.g. metals, concrete), not of a nature to generate GHG emissions from decomposition or incineration.

Summary of Effects

Effect Receptor Impact Magnitude Nature Duration Degree of Identified Sensitivity Effect Construction Effects GHG emissions High Negligible Adverse Short-term Not significant Completed Development Effects

GHG emissions High -232.1 ktCO2e/annum Beneficial Long-term Significant Decommissioning Effects GHG emissions High Negligible Beneficial or Short-term Not significant adverse

Table 6.5: Summary of Effects Prior to Mitigation

6.7 The Predicted Practical Effect of the K3 Proposed Development

Explanatory Note

This assessment represents the practical effect of the K3 Proposed Development application. While the application seeks development consent for the construction and operation of a 75 MW generating station, in reality a 49.9 MW generating station has been constructed and will be operating by end of 2019. Further details are provided in Section 2.8 of Chapter 2.

Construction Effects

No additional construction is required for the practical effect of the K3 Proposed Development and this is scoped out of the assessment.

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Completed Development Effects

The WRATE analysis reported in Appendix 6.1 indicates that the K3 Proposed Development practical effect, increasing the energy output of the consented K3 development and also increasing its waste throughput by 130,000 tonnes per annum (tpa), would provide a net carbon benefit (emissions reduction) of approximately -59.5 ktCO2e/annum compared to the baseline of consented K3 operation and landfill disposal of the 130,000 tpa of waste.

The waste throughput and hence thermal input to the facility would increase by 24.7% while the net electricity export efficiency would increase by 28.3% from 24.4% to 31.2% (a 6.9 percentage point rise). Heat export would be unchanged.

Of the total net -59.5 ktCO2e/annum benefit, -21.3 ktCO2e is from the improvement to the efficiency of the K3 operation, primarily the approximately 60% increase in electricity output from 38.7 MW to 61.8 MW. The avoided burden of landfill disposal contributes -39.0 ktCO2e while a slight increase in transport accounts for the balance of +0.8 ktCO2e.

As a sensitivity test, the WRATE analysis has also considered a scenario with a higher waste NCV of 10.5 MJ/kg while adjusting the assumed composition to keep the 45% biogenic content constant, which is consistent with the main scenario assumption for the WKN Proposed Development. In that scenario, the net benefit of the K3 Proposed Development practical effect would increase to -63.3 ktCO2e/annum due to the greater amount of electricity generated and exported from the higher-CV waste.

Sequestration of the potential fraction of biogenic carbon not decaying in landfill is not a parameter that forms part of the net baseline emissions in the WRATE analysis, as this has fairly high uncertainty. Significant sequestration of biogenic carbon in the landfill baseline would decrease the baseline landfill GHG emissions and hence decrease the net GHG emissions reduction attributable to the K3 Proposed Development from avoided landfill. However, in another area of uncertainty for the baseline, the lifetime landfill gas capture rate, WRATE makes a relatively optimistic assumption of 75%. A lower gas capture rate in practice would lead to higher GHG emissions in the landfill baseline, increasing the net GHG emissions reduction attributable to K3. To a degree these two points may balance out, though this cannot be stated definitively either way as the precise parameters of waste decay in landfill and management of this over a lengthy gas- generating lifetime are difficult to predict for a hypothetical baseline scenario.

The carbon intensity of marginal electricity generation sources displaced is projected to decrease over time in the future baseline, as discussed in Section 6.5. This would reduce the benefit of the additional electricity exported by the K3 Proposed Development. However, even under BEIS projections of very little carbon saved by displacing a marginal generator towards the end of the K3 Proposed Development’s lifetime, the combination of avoided landfill emissions and electricity export would continue to balance the combustion emissions associated with the additional 130,000 tpa throughput. And K3 as consented, with the practical effect of the K3 Proposed Development, would remain a high-efficiency CHP facility that would offer GHG benefits compared to the future baseline over its operating lifetime, as has been shown in Section 6.6.

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In summary, considering the magnitude of GHG emission reductions predicted in the WRATE analysis due to the practical effect of the K3 Proposed Development, and the policy support for CHP and diversion of waste from landfill, it is considered to have a beneficial effect that is significant, applying the definition in paragraph 6.3.25.

Decommissioning Effects

• it is possible that foundations and structures for the K3 Proposed Development could be re-used, incurring no additional GHG emissions attributable to it;

• it is likely that much of K3’s structure and energy generation components have been constructed of steel and other metals with good potential for recycling, in which case the benefits of recycling are attributed to the new material user in BEIS GHG reporting guidance (i.e. not attributed to K3); and

• if disposed of and not recycled, K3’s demolition materials are likely to be mainly inert waste (e.g. metals, concrete), not of a nature to generate GHG emissions from decomposition or incineration.

Summary of Effects

Effect Receptor Impact Magnitude Nature Duration Degree of Identified Sensitivity Effect Construction Effects Scoped out Completed Development Effects

GHG emissions High -59.5 ktCO2e/annum Beneficial Long-term Significant Decommissioning Effects GHG emissions High Negligible Beneficial or Short-term Not significant adverse

Table 6.6: Summary of Effects Prior to Mitigation

6.8 Mitigation

Mitigation of Demolition and Construction Effects

No mitigation recommendations are applicable as the construction for the K3 Proposed Development is already largely completed and no additional construction is required for the practical effect of the K3 Proposed Development.

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Mitigation of Completed Development Effects

Carbon capture and storage (CCS), if feasible for the K3 Proposed Development in future, could offer substantial further GHG emissions reductions , further mitigating climate change effects of the K3 Proposed Development’s direct GHG emissions from that point in its lifetime onwards and making its direct emissions carbon negative due to the sequestration of biogenic carbon. However, the K3 Proposed Development is not required to provide for future CCS readiness in its design, as it falls below the 300 MWe capacity threshold in NPS EN-1 (paragraph 4.7.10).

The K3 Proposed Development will be required under its Environmental Permit to seek continuous improvement in energy efficiency and to provide reports on this to the Environment Agency. The consented K3 facility would already be a high- efficiency CHP facility and the practical effect of the K3 Proposed Development would be to further increase its electrical generation efficiency.

Changes in the composition of waste combusted in the facility to increase the biogenic to fossil carbon ratio, which would be likely if for example the plastic content were reduced in future, would reduce its process emissions and have a beneficial effect provided that the waste CV remained high. This is not within the Applicant’s direct control, but maximising residual biogenic content while retaining an appropriate CV could be influenced through waste supplier contracts.

Overall, however, no further mitigation that is within the Applicant’s control at the K3 site has been proposed or is considered to be required.

Mitigation of Decommissioning Effects

No significant decommissioning-stage effects have been predicted. Nevertheless, in consideration of IEMA guidance that all GHG emissions are potentially significant, and government policy seeking GHG emissions reductions across all economic sectors including construction/demolition, it is recommended that the Decommissioning Environmental Management Plan when written in due course gives consideration to:

• use of an established methodology, such as PAS2080 [Ref. 6.25] and/or life-cycle analysis to consider whole-life impacts of design, including how this will affect decommissioning;

• maximising opportunities for re-use and recycling of materials at the time of decommissioning; and

• efficiencies in decommissioning that can reduce energy, fuel and transport requirements at the time.

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6.9 Residual Effects

Residual effects are those that are predicted to remain after implementation of secondary mitigation measures. The significant residual effects in this case are unchanged as no secondary mitigation of operational emissions is proposed or required.

Significant Receptor Impact magnitude Nature Duration Degree of Level of residual effect sensitivity effect certainty K3 Proposed Development

GHG emissions High -232.1 ktCO2e/annum Beneficial Long-term Significant Limited K3 Proposed Development (practical effect)

GHG emissions High -59.5 ktCO2e/annum Beneficial Long-term Significant Limited

Table 6.7: Residual Effects

6.10 The WKN Proposed Development Predicted Effects

Construction Effects

The WRATE analysis indicates that the embodied carbon of construction materials used would make a very minor contribution to lifecycle impacts, equivalent to <1% of process emissions. Construction stage effects are therefore considered negligible to the overall GHG emission effects and not significant.

Completed Development Effects

The WRATE analysis reported in Appendix 6.2 indicates that the WKN Proposed Development, combusting 390,000 tpa of waste to export up to approximately 311,000 MWh/annum of electricity (35.5 MW), would provide a net carbon benefit (emissions reduction) of approximately -63.8 ktCO2e/annum compared to the baseline of landfill disposal of that waste and alternative electricity generation.

Direct process emissions from waste combustion and transport would be 9, approximately +163 ktCO2e/annum but this would be offset by the electricity exported, displacing approximately -109 ktCO2e/annum, and by the net total 11 avoided landfill burden of approximately -117 ktCO2e/annum .

As a sensitivity test, the WRATE analysis has also considered a scenario with a higher biogenic content of 53% while adjusting the assumed composition to keep the waste NCV of 10.5 MJ/kg constant. In that scenario, the net benefit of the WKN Proposed Development would increase to -98.3 ktCO2e/annum due to the lower fossil carbon emissions from the higher biogenic content waste.

other factors modelled such as the process consumables (other than the waste fuel) and management of the bottom ash (including metals recycling) make relatively small positive and negative contributions to the emissions that tend to roughly balance out. The overall net process emissions total is 161,583 ktCO2e/annum 10 of fossil carbon. Short-cycle biogenic carbon, having a net neutral effect on atmospheric concentration, would be an additional 245,120 ktCO2e/annum. 11 excluding biogenic carbon sequestration

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In a further test, an alternative baseline scenario has been considered in the WRATE analysis in which waste were exported to a typical European EfW with CHP instead of being disposed of in landfill. As would be expected, the higher energy generation efficiency of CHP means that the electricity-only WKN Proposed Development would not achieve carbon savings compared to that baseline, notwithstanding the greater transport-related GHG emissions from waste export.

Sequestration of the potential fraction of biogenic carbon not decaying in landfill is not a parameter that forms part of the net baseline emissions in the WRATE analysis, as this has fairly high uncertainty. Significant sequestration of biogenic carbon in the landfill baseline would decrease the baseline landfill GHG emissions and hence decrease the net GHG emissions reduction attributable to the WKN Proposed Development from avoided landfill. However, in another area of uncertainty for the baseline, the lifetime landfill gas capture rate, WRATE makes a relatively optimistic assumption of 75%. A lower gas capture rate in practice would lead to higher GHG emissions in the landfill baseline, increasing the net GHG emissions reduction attributable to the WKN Proposed Development. To a degree these two points may balance out, though this cannot be stated definitively either way as the precise parameters of waste decay in landfill and management of this over a lengthy gas-generating lifetime are difficult to predict for a hypothetical baseline scenario.

The carbon intensity of marginal electricity generation sources displaced is projected to decrease over time in the future baseline, as discussed in Section 6.5. This would reduce the benefit of the additional electricity exported by the WKN Proposed Development. Under BEIS projections the ‘crossover point’ at which the WKN Proposed Development would no longer be predicted to provide a carbon reduction compared to the baseline (on an annual emissions basis) would be around 2034, 10 years into its 50 year design operating lifetime. In the alternative scenario with higher biogenic carbon content in the waste composition, however, this would not occur and GHG emission reductions compared to landfill and alternative electricity generation throughout the Proposed Development lifetime would continue to be predicted. This illustrates the high sensitivity of the assessment to assumed waste composition and biogenic carbon content.

In summary, considering the magnitude of GHG emission reductions predicted in the WRATE analysis due to the WKN Proposed Development and the policy support for diversion of waste from landfill, the Proposed Development is considered to have a beneficial effect that is significant, applying the definition in paragraph 6.3.25.

Decommissioning Effects

The WRATE analysis indicates that decommissioning would make a very minor contribution to lifecycle impacts, equivalent to <0.1% of annual process emissions, so this is considered negligible and not significant. The points made in paragraph 6.7.10 for the K3 Proposed Development are also applicable to the WKN Proposed Development.

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Summary of Effects

Effect Identified Receptor Impact Magnitude Nature Duration Degree of Sensitivity Effect Construction Effects Not GHG emissions High Negligible Adverse Short-term significant Completed Development Effects

GHG emissions High -63.8 ktCO2e/annum Beneficial Long-term Significant Decommissioning Effects Beneficial or Not GHG emissions High Negligible Short-term adverse significant

Table 6.8: Summary of Effects Prior to Mitigation

6.11 Mitigation

Mitigation of Construction Effects

Construction-stage effects are not predicted to be material to the total life-cycle effect of the WKN Proposed Development. Nevertheless, in consideration of IEMA guidance that all GHG emissions are potentially significant, and government policy seeking GHG emissions reductions across all economic sectors including construction, in general terms it is recommended that the Applicant considers implementing the following additional mitigation measures during detailed design:

• seek a reduction in total materials required and hence embodied carbon through lean/efficient design;

• specify materials with low embodied carbon (e.g. based on data in the BRE Green Guide to Specification [Ref. 6.26] or product EPDs);

• source materials locally where possible to reduce transport GHG emissions; and

• consider use of an established methodology, such as BREEAM New Infrastructure [Ref. 6.27], PAS2080 [Ref. 6.28] and/or life-cycle analysis to guide low-carbon design and construction, set a feasible reduction target and quantify its achievement.

Mitigation measures recommended in Section 5.11 of Chapter 5: Air Quality for inclusion in the CEMP to reduce air pollutant emissions during construction will also offer mitigation of GHG emissions from construction plant and waste.

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Mitigation of Completed Development Effects

CCS, if feasible for the WKN Proposed Development in future, could offer substantial further GHG emissions reductions12, further mitigating climate change effects of the WKN Proposed Development’s direct GHG emissions from that point in its lifetime onwards and making its direct emissions carbon negative due to the sequestration of biogenic carbon. However, the WKN Proposed Development is not required to provide for future CCS readiness in its design, as it falls below the 300 MWe capacity threshold in NPS EN-1 (paragraph 4.7.10).

Changes in the composition of waste combusted in the WKN Proposed Development to increase the biogenic to fossil carbon ratio, which would be likely if for example the plastic content were reduced in future, would reduce its process emissions and have a beneficial effect provided that the waste CV remained high. This is not within the Applicant’s direct control, but maximising residual biogenic content while retaining an appropriate CV could be influenced through waste supplier contracts. Paragraphs 6.10.4 and 6.10.7 highlight the benefits that this could provide.

The WKN Proposed Development is designed to be CHP-ready and also has potential to act as a standby for the K3 CHP facility when that is undergoing maintenance. Future CHP opportunities for the WKN Proposed Development would have the potential to significantly increase its energy efficiency, providing greater carbon reductions due to displaced heat generation and ameliorating the decline in carbon reductions afforded by electricity export over time as the future baseline for this decarbonises. This would be similar to the case for the K3 Proposed Development, discussed in paragraph 6.7.7. CHP opportunities aside, the WKN Proposed Development will have a general duty under its Environmental Permit to seek continuous improvement in energy efficiency and to provide reports on this to the Environment Agency.

Overall, however, given the GHG emission benefits that the WKN Proposed Development is predicted to offer during its initial years of operation, no further mitigation that is within the Applicant’s control at the development site has been proposed or is considered to be required at this stage.

Mitigation of Decommissioning Effects

No significant decommissioning-stage effects have been predicted. Nevertheless, the recommended considerations for the K3 Proposed Development specified in paragraph 6.8.6 apply equally to the WKN Proposed Development.

6.12 Residual Effects

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Significant Receptor Impact magnitude Nature Duration Degree of Level of residual effect sensitivity effect certainty

GHG emissions High -63.8 ktCO2e/annum Beneficial Long-term Significant Limited

Table 6.9: Residual Effects

6.13 Cumulative Effects

The sensitive receptor affected by the effects of both the K3 and WKN Proposed Developments is the ‘global atmospheric mass of the relevant GHGs and consequent warming potential, expressed in CO2-equivalents’ and its ‘high’ sensitivity has been defined taking into consideration the cumulative effects of all anthropogenic GHG emissions.

The atmospheric concentration of GHGs and resulting climate change is affected by all sources and sinks globally, anthropogenic and otherwise. As GHG impacts are global rather than affecting one localised area, all cumulative sources are relevant: this is taken into account in the defined ‘high’ sensitivity of the receptor to impacts from any development.

With regard to the interactions of the K3 or WKN Proposed Developments with other GHG emission sources affected (i.e. other waste treatment and energy generation), this has formed part of the assessment and the net change in emissions has been reported above.

Cumulative effects from other specific individual developments are therefore not separately assessed. No additional cumulative effects of greater significance than reported above, due to other specific local development projects or the combination of the K3 and WKN Proposed Developments, are predicted.

6.14 Summary

The likely significant effects of greenhouse gas (GHG) emissions from the K3 and WKN Proposed Developments have been assessed in this Environmental Statement chapter. The global atmospheric mass of relevant GHGs and consequent warming potential, expressed in CO2-equivalents, has been considered as a high sensitivity receptor affected by each of the K3 and WKN Proposed Developments.

Net total GHG emissions from operation of the K3 and WKN Proposed Developments have been calculated based on their waste throughput, combustion processes and treatment of residues. These emissions have been compared to baseline GHG emissions from landfill disposal of waste and from conventional electricity and heat generation.

Construction– and decommissioning–stage impacts have also been evaluated and are considered not to be material to the total GHG emissions over the K3 and WKN Proposed Developments’ lifetimes, which are dominated by the combustion of waste and generation of energy. The K3 Proposed Development is in any case already largely constructed.

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The significance of the impacts of net GHG emissions from the K3 and WKN Proposed Developments has been evaluated with regard to change from the baseline and in the context of climate change and waste policy.

All calculations of GHG emissions have been undertaken with the waste sector life-cycle analysis software tool ‘WRATE’. The WRATE calculations are reported in Appendices 6.1, 6.2 and 6.3.

Key uncertainties and limitations to the assessment concern the estimate of GHG emissions from landfill in the baseline scenario, the carbon intensity of marginal electricity generation in the baseline that is displaced, and the characteristics of the waste managed (its biogenic to fossil carbon ratio and its energy content), which affect both the baseline and the K3 and WKN Proposed Development scenarios.

The K3 Proposed Development is predicted by the WRATE analysis to cause total emissions of approximately 255 thousand tonnes of fossil carbon-dioxide equivalent (ktCO2e) per year of operation. However, compared to the baseline of landfill waste disposal and electricity generation that it would avoid, the net effect of the K3 Proposed Development as a whole is predicted to be a reduction in GHG emissions of 232 ktCO2e/annum, which would be a beneficial effect that is considered significant.

The practical effect of the K3 Proposed Development, increasing the energy output of the consented K3 development and also increasing its waste throughput by 130,000 tonnes per annum, is predicted by the WRATE analysis to cause a net total GHG emissions reduction of approximately 60 ktCO2e per year of operation. This is the balance of process emissions from waste combustion, transport and facility operation compared to the baseline of landfill waste disposal and electricity generation that it would avoid. The predicted 60 ktCO2e per annum net GHG emission reduction would be a beneficial effect that is considered significant.

Although unavoidable uncertainties in the estimation of baseline waste management and displaced electricity generation emissions limit the precision and certainty with which the net benefits of the K3 Proposed Development practical effect (increases to the consented K3 facility waste throughput and electricity generation) can be predicted, the K3 Proposed Development as a whole can be said with higher confidence to perform well in GHG emission terms due to its efficiency as a combined heat and power (CHP) facility.

The WKN Proposed Development is predicted by the WRATE analysis to cause a total of approximately 163 ktCO2e per year of operation.

However, compared to the baseline of landfill waste disposal and electricity generation that it would avoid, the net effect of the WKN Proposed Development is predicted by WRATE be a GHG emissions reduction of approximately 64 ktCO2e per annum. The predicted 64 ktCO2e per annum net GHG emission reduction would be a beneficial effect of the WKN Proposed Development that is considered significant.

There are unavoidable uncertainties in the estimation of baseline waste management and displaced electricity generation emissions which could affect the net GHG balance predicted for the WKN Proposed Development. Based on the

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Wheelabrator Technologies Inc Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order

WRATE analysis, a net GHG emissions reduction is considered more probable than a net emissions increase compared to the baseline, but the amount can only be stated with limited confidence as it is highly sensitive to the assumptions applied.

In the case of both the K3 and WKN Proposed Developments, potential further mitigation measures have been considered, but no additional mitigation for the operational phase that is within the Applicant’s control at the development site has been proposed or is considered to be required.

Notwithstanding the limited materiality of construction- and decommissioning- stage emissions to the total, good-practice measures to reduce GHG emissions have been recommended for the WKN Proposed Development, consistent with IEMA guidance that any GHG emissions (and hence opportunities for reductions) may be significant.

As GHG impacts are global, all cumulative sources are relevant: this is taken into account in the defined ‘high’ sensitivity of the receptor and statement that any additional GHG emissions may be considered significant. Additional cumulative effects of greater significance than reported above, due to other specific local development projects or the combination of the K3 and WKN Proposed Developments, are therefore not predicted.

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Wheelabrator Technologies Inc Wheelabrator Kemsley (K3 Generating Station) and Wheelabrator Kemsley North (WKN) Waste to Energy facility Development Consent Order References

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