Response 608235559

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4. Please provide your comments on the environmental permit application received from East Kent Recycling Limited

Please provide your comments on the environmental permit application received from East Kent Recycling Limited (Required)
I object strongly to the proposed expansion of the East Kent Recycling (EKR) operation at Oare, in particular on the grounds of negative environmental impacts on the neighbouring Site of Special Scientific Interest (SSSI), Special Protection Area (SPA), and Ramsar site (a wetland of international importance designated under the Ramsar Convention). My detailed comments below will focus on UK government obligations under the Ramsar Convention, but similar commitments and obligations exist in relation to SSSI and SPA listing and must also be taken into consideration in relation to approval of this permit. The EKR site is immediately adjacent to the Swale Ramsar site, which was designated in 1985 in recognition of the high species diversity of plants and invertebrates of its saltmarshes and mudflats, including several nationally rare species. The area is of national importance for breeding, migrating and wintering ducks and waders, and regularly supports internationally important numbers of numerous species of wintering waterbirds. See http://jncc.defra.gov.uk/pdf/RIS/UK11071.pdf for a detailed description of the importance of the Swale as a Ramsar site according to the UK Joint Nature Conservation Committee (JNCC). As a Contracting Party to the Ramsar Convention since 1976, under Article 3 of this legally-binding international treaty the government of the United Kingdom commits to "promote the conservation of the wetlands included within the [Ramsar] List" and "the wise use of wetlands within their territory." Any proposed development that might affect the Swale Ramsar site must therefore be carefully reviewed to ensure that it does not lead, even unintentionally, to negative environmental impacts affecting in particular the characteristics that contributed to the listing of the site in 1985. Such impacts include, but may not be limited to: - Noise and dust emanating from the EKR site, disturbing local human residents, wildlife and the Saxon Shore Way that borders site. The proposed new plant is likely to be much noisier and to generate more dust. An enforceable decibel limit should be included in any operating permit for the EKR site, along with enforceable quantitative and qualitative limits on emissions of airborne particulate matter. - Local people have reported discolouration of the lagoon into which the existing East Kent Recycling plant already discharges water. Regular and thorough laboratory analyses to check for toxic pollutants in discharges must be required under any permit for the EKR site, both into the lagoon and into the neighbouring Oare creek, and unannounced spot checks conducted by the Environment Agency. Routine analyses and spot checks must be underpinned by explicit and enforceable limits on organic and inorganic pollutants. - Light pollution from the EKR site, already an issue for local residents and recreational users of the nearby creek and Ramsar site, will become a more significant problem if the site is allowed to operate from 05h00 to 20h00 as requested. It is well-documented in scientific literature that birds and other animals may experience increased orientation or disorientation as a result of artificial light and can be attracted to or repulsed by glare, with consequences for foraging, reproductive, communication and other critical behaviours. Artificial light can also disrupt interspecific interactions that have evolved in natural patterns of light and dark, with serious implications for community ecology. A site-specific environmental impact assessment should be conducted of the EKR site to measure the impact of existing light pollution on wildlife associated with the nearby Ramsar site, and the potential additional impact that would be associated with the longer operating hours that are being proposed. Mitigation measures may need to be taken as a result, e.g. in the design and power of artificial lighting. Regular wildlife monitoring should be required under any new permit in order to detect any negative impacts that would contravene the British government's legal commitments as a Contracting Party to the Ramsar Convention.