Seeking your views
4. Please provide your comments on the environmental permit application received from Indaver Rivenhall Limited
Please provide your comments on the environmental permit application received from Indaver Rivenhall Limited
(Required)
CO5 9DF, Indaver Rivenhall Limited: environmental permit application advertisement – EPR/CP3906LP/V003
My name isRedacted text and I am the Redacted text for the Braintree Eastern division which includes the IWMF site at Rivenhall Airfield and several communities including Kelvedon, Feering, Coggeshall, Stisted, Cressing and east Braintree which are less than 5km from the IWMF site. I’m also one of the Redacted text for the Kelvedon & Feering ward; the IWMF is situated in the parish of Kelvedon. I alsoRedacted text Redacted text Redacted text which meets quarterly withRedacted text Redacted text.
I would like to make the following comments and objections to the proposed changes:
1. The phased construction and operation of the IWMF: I have major concerns about the phased construction and operation of the IWMF. When the IWMF was granted planning permission the waste incinerator plant only formed about one sixth of the planned integrated site. When the EA granted the existing Environmental Permit in 2020, the EA had assumed that ALL of the buildings associated with the Rivenhall IWMF were going to be constructed from the outset. This has not been the case. Indaver has only built the waste to energy plant (the 595,000 tonnes of waste per year incinerator). Indaver says it will construct the other elements in a phased manner but no planning applications have been submitted. It is my view, Indaver will never build any of these other elements of the IWMF. Therefore the “phased” construction of the site means the emissions from the 35-metre stack will be different from how the EA originally envisaged due to the lack of steam from the non-existent paper pulping plant and the lack of buildings for the other waste processing elements. The waste incinerator at Great Blakenham near Ipswich, which was opened in 2014, has a stack 85-metres high; I am deeply concerned that the “phased” construction of the waste treatment and processes and the buildings at Rivenhall Airfield will influence the dispersion of emissions from the stack and a new air quality assessment must be carried out by the EA to reassure local communities that the emissions won't be harmful to human health in our communities, local crops and the local natural environment. The EA should also review whether the Rivenhall Airfield stack, which is only 35-metres above ground level, is high enough to protect the health of local communities. My personal view is that I’d rather be looking at an 85-metre stack than a 35-metre stack if that meant local communities were better protected from toxic emissions. In short, I'd rather see the stack than breathe in the emissions.
2. Introducing an emission point to the River Blackwater to allow for the discharge of uncontaminated surface water run-off from Upper Lagoon.
The non-existent permitted paper pulp process was going to be a significant consumer of water. It has not been built and there are no plans to build it. To minimise the consumption of mains water it was proposed to harvest rainwater and process effluents from the different waste treatment processes for re-use within the pulp plant. On this basis, the Rivenhall IWMF was conceived as having zero-discharges to water, with surface water run-off being collected in Upper Lagoon to enable it to be harvested for re-use within the Rivenhall IWMF.
With the “phased” construction of the Rivenhall IWMF, there will not be a use for run-off water from the IWMF. As a result, it will be necessary to discharge “uncontaminated” surface water run-off from building roofs and areas of hardstanding collected in Upper Lagoon to the River Backwater. I put the word “uncontaminated” in inverted commas because an Indaver engineer told members of the ECC Development and Regulation committee during a site visit on January 24 2025 that rainwater run-off from the incinerator site could be contaminated with lime and urea that is used in the emissions scrubbing process. I also have concerns about contamination from all the vehicles using the site. Local communities need reassurance that the surface water won't contain pollution contaminants and the water won't be released into the River Blackwater when there is a flood risk in Coggeshall, Feering and Kelvedon i.e. water will be stored when river levels are high and released when low.
Also, the EA is looking at submitting an application for a flood alleviation scheme at Coggeshall that necessitates Essex's largest quarry being dug out at Grange Farm. The Upper Lagoon is a large hole in the ground that already exists; if controlled properly ie emptied when river levels are low, it could be filled when river levels are high making the need for a flood scheme/quarry redundant.
3. Removing the electricity generation limit to align the permit with the recently consented Development Consent Order.
I don’t have any concerns with the proposed increase in electricity generation capacity IF it means there won’t be an increase in the permitted mount of waste that can be incinerated ie a max of 595,000 tonnes per year as already permitted.
4. The processing of additional non-hazardous EWC codes within the CHP Plant.
Indaver describes this additional waste as "non-hazardous" but I’m very concerned about this because the new requested codes include plastic packaging, composite packaging, absorbents, plastics, medicines, sludges from industrial waste water not already permitted, detergents, paints, inks adhesives and resins that are not already permitted and biodegradable waste. We need to know that these wastes are compatible with the existing height of the smoke stack (only 35-metres) and the “phased” construction of the permitted waste processes and won't be harmful to human health in our communities, crops and the natural environment.
My name is
I would like to make the following comments and objections to the proposed changes:
1. The phased construction and operation of the IWMF: I have major concerns about the phased construction and operation of the IWMF. When the IWMF was granted planning permission the waste incinerator plant only formed about one sixth of the planned integrated site. When the EA granted the existing Environmental Permit in 2020, the EA had assumed that ALL of the buildings associated with the Rivenhall IWMF were going to be constructed from the outset. This has not been the case. Indaver has only built the waste to energy plant (the 595,000 tonnes of waste per year incinerator). Indaver says it will construct the other elements in a phased manner but no planning applications have been submitted. It is my view, Indaver will never build any of these other elements of the IWMF. Therefore the “phased” construction of the site means the emissions from the 35-metre stack will be different from how the EA originally envisaged due to the lack of steam from the non-existent paper pulping plant and the lack of buildings for the other waste processing elements. The waste incinerator at Great Blakenham near Ipswich, which was opened in 2014, has a stack 85-metres high; I am deeply concerned that the “phased” construction of the waste treatment and processes and the buildings at Rivenhall Airfield will influence the dispersion of emissions from the stack and a new air quality assessment must be carried out by the EA to reassure local communities that the emissions won't be harmful to human health in our communities, local crops and the local natural environment. The EA should also review whether the Rivenhall Airfield stack, which is only 35-metres above ground level, is high enough to protect the health of local communities. My personal view is that I’d rather be looking at an 85-metre stack than a 35-metre stack if that meant local communities were better protected from toxic emissions. In short, I'd rather see the stack than breathe in the emissions.
2. Introducing an emission point to the River Blackwater to allow for the discharge of uncontaminated surface water run-off from Upper Lagoon.
The non-existent permitted paper pulp process was going to be a significant consumer of water. It has not been built and there are no plans to build it. To minimise the consumption of mains water it was proposed to harvest rainwater and process effluents from the different waste treatment processes for re-use within the pulp plant. On this basis, the Rivenhall IWMF was conceived as having zero-discharges to water, with surface water run-off being collected in Upper Lagoon to enable it to be harvested for re-use within the Rivenhall IWMF.
With the “phased” construction of the Rivenhall IWMF, there will not be a use for run-off water from the IWMF. As a result, it will be necessary to discharge “uncontaminated” surface water run-off from building roofs and areas of hardstanding collected in Upper Lagoon to the River Backwater. I put the word “uncontaminated” in inverted commas because an Indaver engineer told members of the ECC Development and Regulation committee during a site visit on January 24 2025 that rainwater run-off from the incinerator site could be contaminated with lime and urea that is used in the emissions scrubbing process. I also have concerns about contamination from all the vehicles using the site. Local communities need reassurance that the surface water won't contain pollution contaminants and the water won't be released into the River Blackwater when there is a flood risk in Coggeshall, Feering and Kelvedon i.e. water will be stored when river levels are high and released when low.
Also, the EA is looking at submitting an application for a flood alleviation scheme at Coggeshall that necessitates Essex's largest quarry being dug out at Grange Farm. The Upper Lagoon is a large hole in the ground that already exists; if controlled properly ie emptied when river levels are low, it could be filled when river levels are high making the need for a flood scheme/quarry redundant.
3. Removing the electricity generation limit to align the permit with the recently consented Development Consent Order.
I don’t have any concerns with the proposed increase in electricity generation capacity IF it means there won’t be an increase in the permitted mount of waste that can be incinerated ie a max of 595,000 tonnes per year as already permitted.
4. The processing of additional non-hazardous EWC codes within the CHP Plant.
Indaver describes this additional waste as "non-hazardous" but I’m very concerned about this because the new requested codes include plastic packaging, composite packaging, absorbents, plastics, medicines, sludges from industrial waste water not already permitted, detergents, paints, inks adhesives and resins that are not already permitted and biodegradable waste. We need to know that these wastes are compatible with the existing height of the smoke stack (only 35-metres) and the “phased” construction of the permitted waste processes and won't be harmful to human health in our communities, crops and the natural environment.