The report to these Appendices is available as the text/Word version Appendix I To PTE/11/6 Appendix II To PTE/11/6 Appendix II to Report PTE/11/6: Responses from Statutory and Technical Consultees Representation Substance of response Original Response Reg 19/Further Response 1. Highways Agency (19.4.10) 1. The selected option for access arrangements is satisfactory subject to confirmation on impacts within the TA (applicant has been asked for additional information direct). 2. HA will need to be assured that traffic calming measures along New Park Road will not lead to backing up of traffic onto the trunk road. 3. Clarification is required that all of the traffic calming and access road will be delivered prior to commencement of the EfW to minimise impact of construction traffic. 4. HA wish to know how WPA will control the tonnage of material being brought to the site and seek an appropriate condition to avoid future impacts on the SRN. 5. The TA does not include any indication of the proposed impact on the mainline flow of the A38 and it is important to understand that the slip roads can accommodate the additional HGVs and whether there would be an adverse impact on vehicle weaving on the A38. 1. Highways Agency Still a number of issues not addressed by the TA addendum: 4.4.11 Two proposed changes to the application have the potential to result in a material impact on the safe and efficient operation of the SRN: 1. Duration of landfill (increased by 5 years to 2043) 2. Capacity of void increased from 825,000sqm to 970,000sqm HA requires analysis demonstrating likely impact of revised proposals on the safe and efficient operation of the SRN. HA requires clarification that the new access road and traffic management works will be constructed prior to the commencement of on site construction to mitigate the impacts of construction traffic (condition?) HA requires clarification that the submitted capacity of 275,000tpa is not exceeded in the light of the potential impact of any increase on the SRN The HA is now aware that the proposal is actually in the region of 338ktpa including C&I waste and other materials?) HA require additional information concerning peak flows on the west bound off slip. HA require additional information from the applicant concerning potential impact from personal transport during construction phase. HA require a sensitivity test to determine a cap on the expected number of HGV trips as submitted information on HGVs is inconsistent. HA wish to have a legal agreement not to implement the quarrying permission (Being pursued by DCC) 1. Highways Agency Supplementary Response 9.5.11 Works in relation to the proposed access will need to be secured by Grampian Condition; HA not satisfied with response to query about how the tonnage will be restricted to 275,000tpa and wish to clarify how this would be achieved by DCC. 2. Friends of the Earth (19.4.10) 1. Statement of Community Involvement The SCI produced by Viridor does not meet the requirements for proper SCI. This is confusing “misinformation”. 2. The application gives the impression that recycling will take place at the facility due to the naming of the facility. This is considered to be misleading as the only “recycling” relates to IBA. 3. Figures used in the documentation are inconsistent (examples given). 4. ES not put together in such a way as to be helpful. 5. Proposal is contrary to PPS1 due to existing environmental constraints/ancient woodland/River Yealm. 6. Incineration is not a prudent use of natural resources and will undermine recycling & cause pollution. 7. Focus should be on composting and increasing recycling rates through the SWDWP area so that it meets the same rates of .50% that SHDC has achieved. Appendix II to Report PTE/11/6: Responses from Statutory and Technical Consultees 8. Viridor’s modelling of alternatives (Section 14) is very limited and does not include AD as supported by DEFRA’s waste strategy (2007). 9. The “potential” use of heat doesn’t equate to an actual use. 10. Comparing the carbon footprint only with landfill is misleading as all options are better than landfill. 11. CO2 emissions from transportation to and from the site have not been factored into the overall environmental footprint which ignores 10 million tonnes of rubbish being moved on the roads during the 25 year contract period. 12. If recycling rates reduce then waste will still have to be transported to the site – there is no convincing modelling of transportation over the life of the incinerator. 13. Waste recovery is too far down the waste hierarchy and the proposal contravenes the principles of PPS10. Alternatives do not consider strategies the reduction of residual waste or its modelling. 14. The long fixed contracts being offered by the SWDWP will stifle innovation and not drive waste reduction. 15. The proposed incinerator will not contribute to sustainable communities, will pollute the atmosphere causing harm to human, animal and plant life. 16. The importation of waste from a wide area contradicts the “proximity principle”. 17. TA is very confusingly set out. 18. Modelling of freight movements is limited and the conclusion that the traffic movements are acceptable in traffic and transport terms is not justified. 19. There is no HGV management plan for the operational phase. 20. No analysis of impact of additional HGVs coming from Torbay – would they go through Totnes AQMA – any routing agreement? 21. Even if the general increase in traffic is 2.6%, a 45.2% increase in HGV movements through Lee Mill is unacceptable. 22. The proposal does not promote access by modes other than the car and is therefore contrary to PPG13 and PPG1 which require the consideration of sustainable transport. 23. There will be no walking or cycling routes to the site. 24. The LVI section is subjective in its justification of the proposal. 25. The proposal is contrary to PPS9 in its damaging impact on ancient woodland and habitat areas. 26. The unacceptable impact on the sensitive River Yealm both from leachate from the site and drainage ditches. 27. Impacts on the Yealm would have an impact on bat foraging and this will be inevitable during the construction phase. This is contrary to the habitat regulations and permission should not be granted. 28. The proposal is contrary to the Habitats Regulations due to the unmitigated impacts on bats. 29. The proposal fails the sequential test for essential infrastructure as the access road will be impassable in times of flood. 30. The application is contrary to Government Policies in PPS1, PPS9, PPS10, PPG13; PPS23 and PPS25 and the treatment method is outmoded. 2. Friends of the Earth (5.4.11) Reg 19 response R19.1 Alternatives still not fully modelled; no landfill gas capture (despite landfill being available for putrescible waste); landfill gas not modelled into the CO2 calculations; no use of heat. R19.9 No mention of lorry routeing through Totnes – no indication of routes for Torbay Waste. R19.10 Predicted traffic impacts are meaningless in the light of uncertainty about C&I waste arisings. R19.12 Traffic impacts in construction and operation stage should be modelled into the carbon footprint calculation Using existing transport distances to landfill in no justification for maintaining the status quo - the EfW should demonstrate a significant reduction in transport associated CO2 emissions and does not. R19.17 Recent DEFRA survey revised down the amounts of CIW available. R19.50 Response on Dartmoor SAC is inadequate and unclear. Concern about nano particles smaller than PM10 – no research and therefore no certainty. Impact on Dartmoor SAC from particulates from high speed traffic on A38; Waste sorting not foolproof and therefore the facility will burn lead, cadmium and mercury leading to its content in Appendix II to Report PTE/11/6: Responses from Statutory and Technical Consultees residue ash and particulates. Different waste streams will mean different emissions therefore not possible to determine impact on SAC; cumulative impacts with Langage and Hemerdon detrimental. R19.98 Recycling options within the facility remain unclear – no indication of what will happen to materials unsuitable for recycling. R19.99 Answer incomplete. Assumed quantities of waste going to landfill not calculated nor have CO2 or CH4 emissions & no provision for gas capture. 3. Government Office for the Refer to regulation 21 of the T&CP (EIA) Regs 1999 which require the LPA to notify the Secretary of State of any decision taken. Request South West (23.2.10) copy of decision notice and any conditions. 4. South West Water (22.2.10) No objection 4. South West Water Reg19 No further comment Response (18.02.11) 5. RSPB (4.3.10) Provide advice on retention and compensation of bird habitat. 5. RSPB (11.4.11) Suggest submission of detailed scheme to form part of a condition 6. South West Councils Will only respond if they consider there are significant issues relating to general conformity or general alignment with the RSS. (Regional Planning Body) (24.2.10) 7. Devon County Mineral/Waste Policy (22.2.10) 7 Devon County Waste Policy Broad assessment of policy fit at Regional Strategic and Local level but no conclusions/recommendation. 8. Commission for Architecture Unable to review proposal due to limited resources – suggest referral to Regional Design Review Panel. and the Built Environment (Subsequent discussion with Timothy Cantrell of the RDP indicated that as they have already seen the initial design and commented on it they (08.3.10) would not have anything significant to add – by e-mail 24.3.10).