We are concerned about the above application, as we believe it contains a great deal of misleading information, which may contribute to a favorable bias, both to the planning committee and also the supporting statements.
1. The plant is described as a biomass CHP plant ( CHP–combined heat and power ) …..these plants can be 70-90% efficient
The primary source of fuel is waste wood, not wood from agricultural waste or forestry
There is no proposal to use the thermal energy which is c 75% of the total energy output- sufficient to heat nearly 30,000 homes, as such it is not a CHP plant, this also makes it c 20% efficient
In the absence of any process detail, the report fails to mention how this thermal energy will be dissipated eg cooling tower with resultant steam cloud etc etc
2 Quantity of Wood required , and the impact on transport and noise
The QC indicates that the plant will use 85,000 tonnes per annum. However other areas of the report suggest the volume will be 150,000 tonnes. The latter figure is more likely.
It states that the wood may derive from Armstrong’s site, who are processing 120,000 tonnes of timber and 70,000 tonnes of green wood waste per annum. Figures from the environment agency show Armstrong’s as receiving only 76,000 tonnes of total waste in the last year, and an average of 71,000 tonnes per annum over the last three years. Not all of this quantity is wood.
It is therefore probable that the number of deliveries would need to be increased over 100%
The supporting statement further mentions on two occasions that the total quantity of wood may not originate form Armstrong’s, ie there would be increased deliveries of 150,000 tonnes per annum – a 200% increase. Irrespective of vehicles leaving with processed waste or empty.
This is totally inconsistent with the supporting transport and noise statement, which even suggest transport will decrease.
3 Emissions
Environmental Risk Assessment (EPR-H1 part 2) and the Waste Incineration Directive (WID) require the emissions originating from a proposed development to be defined and in what quantities. The study has just used the limits defined in the WID, even though the WID states that this should not be done.
For a new installations estimates of releases are required. where possible, estimates of releases should be backed up by information from pilot trials or similar operations. This has not been done.
The assessment should consider the Meteorology and local topography i.e.
The wind speed and direction data used is from south Manchester so it is not relevant to this location.
Rainfall levels have not been considered even though this would be a significant route for pollutants to enter the SSSI.
Temperature – no data provided
In a valley – not mentioned
EPR-H1 part 2 defines lower levels than specified in the report to protect vegetation and ecosystems in an SSSI. The adjacent Red Moss is an SSSI
• NOx value 30 µg/M3 not 40 µg/M3
SO2 value 20 µg/M3 not 125 µg/M3
In addition the background pollutant levels are measure in Wigan and Manchester, rather than Horwich / Blackrod / Bolton. No account is made of the recent planning approval on the Markland Farm Biomass plant.
The statement stresses that an Environmental Impact Assessment (EIA) is not required, but the EIA guidance document suggests quite the opposite. Especially as the current application does not clearly identify the likely emissions and in what quantities they can de expected.
It is clear that there a number of significant errors / omissions / contradicting statements within the application. In the absence of clarification on these points the current application cannot be acceptable
Please see the Planning application link on the right hand side of thi s page
