Errors found in additional information for Second Blackrod Power Plant

BLACKROD POWER PLANT UPDATE: Errors have been identified in the addtional information suplied in respect of Blackrod Power Plant and the serious impact on nearby residents, by BHEAG

 

Tuesday, 04 October 2016
Dear Sir / Madam,
We would like to draw your attention to errors in the supplemental information offered in support of application 97291/16.
The applicant states that “In short, it is considered highly unlikely that background NO2 concentrations at the Moss Lane flat have been underestimated by as much as 15.7 μg.m-3”.
The flats are on the edge of an AQMA whilst the actual background level is unknown it is certain that the levels are greater than 35 μg m-3 (This being the threshold for an AQMA area). The use of 20 μg m-3 as a background pollution level is therefore not acceptable for these properties.
Substituting the figure of 35 μg m-3 in the applicant’s calculations drastically reduces the headroom for short term exposure and equals the maximum long term exposure level. These figures are a great cause for concern especially as it is likely that the background levels are likely to be greater than 35.0 μg m-3.
The assessment of baseline conditions in the original assessment derived a long-term background NO2 concentration of 35.0 μg m-3. In this case, the short-term background concentration would therefore be 35.0 x 2 = 70.0 μg m-3. When this is added to the PC at Moss Lane, the PEC becomes 70.0 + 80.1 μg m-3 = 150.1 μg m-3.
The highest process contribution of 4.2 μg m-3 at Moss Lane represents 11% of the annual-mean limit value of 40μg.m-3. The assessment of baseline conditions in the original assessment derived a long-term background NO2 concentration of 35.0 μg m-3. Adding the PC of 4.2μg.m-3 to the background concentration of 35 μg m-3 gives a total predicted environmental concentration of 39.2 μg m-3, which falls into the ‘Substantial’ long-term impacts category.
Persons using the footpaths surrounding the facility would be subjected to much higher levels of pollution than even those living on Moss lane, should the short term pollution levels experienced on the footpaths not also be shown?
The assessment ignores the pollution implications on operations at the adjacent facility. Portakabin office blocks and outdoor working areas are very close to the proposed development so the assessment should have included an assessment of any impacts on the individuals working close to the facility.
Blackrod and HorwichEnvironmental Action GroupTwo Communities – One Cause
The use of background pollution levels from the DEFRA model and wind information for any of the 3 remote locations stated is wholly inappropriate and as such it gives no confidence in the report’s findings.
The IAQM guidelines state that “In some cases, it may be appropriate to carry out a period of air quality monitoring as part of an air quality assessment. This may be particularly helpful where new relevant exposure is proposed in a location with a complex road layout and/or topography, which may be difficult to model, or where there are no data available to verify the model“.
Detailed modelling (iaw LAQM.TG (09)) is appropriate in this case due to the proximity of the AQMA.
We believe the proximity of the SSSI also supports the requirement for detailed monitoring. A line source of NOx runs along the southern border of the moss that is known to have an annual mean level of greater than 35.0 μg m-3 (the AQMA threshold). As this is already greater than the SSSI critical annual mean level (30.0 μg m-3) it is clear the any further emissions will only serve to cause increased harm to the SSSI.
Supplemental Noise Assessment
The supplemental noise information offered by the applicant is totally irrelevant as it is nothing more than a statement of the analyst’s judgement.
The noise survey was not carried out in a satisfactory manner as
1) Noise measurements were not carried out in a suitable location. The location LT1 does not provide a barrier to motorway noise similar to that found in the amenity area of the flats.
2) No calculations of noise experienced by these flats has been provided merely a statement that the” development will not result in adverse impact the amenity of nearby residents”. (i.e. without monitoring and detailed calculations, including the impact of the building’s façade).
3) The fact that development noise will not be continuous has been ignored. Random noise is highly noticeable and intrusive.
4) The assessment also makes assumptions regarding the operations at the adjacent facility that they are in no position to.
Yours faithfully
BHEAG

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