Further memorandum submitted by the Environment Agency (AQ 30)


Submission made by Allan G Norman to Environmental Audit Committee:


"The recent example of the granting of a licence to Prenergy for a large woodchip power station in the town shows quite clearly that the Environment Agency sees one of its primary responsibilities under the Environment Protection Act 1995 as "to make a contribution towards attaining the objectives of achieving sustainable development" as determined by ministers, even when the ministers are obviously wrong. It has accepted dubious computer modelling data and set spurious limitations on the pollution arising from the new plant that it knows cannot be achieved by the company in the knowledge that the source of the PM10s or PAHs cannot be proven. Therefore, no action will be taken against the company even if the pollution in the town exceeds even more the guidelines set by Europe and the UK government. There is a complete lack of trust in the Environment Agency."


[Emphasis added by Environment Agency]


The Environment Agency's response:


Permitting of the installation


We issued the environmental permit to Prenergy Power Ltd on 29 September 2009, but we would not expect the installation to be operational until 2013. The decision to grant a permit followed a lengthy evaluation process and discussions with local people. We also sought the advice of the Local Health Board and we set strict emission limits to protect human health. The strict emission limits are important given the proximity of the Air Quality Management Area for particulates in Port Talbot.


We are confident that the modelling data on which we based our decision to issue the Prenergy permit gives realistic predictions of the impact of the site. Extensive work was undertaken by our Air Quality Modelling and Assessment Unit to ensure that the computer modelling data was sufficiently reliable to allow us to base our decision on it, taking into consideration conservative error margins.


The site will have only one main point source and negligible fugitive emissions of PM10 particulates. All dusty materials on the site will be handled within totally enclosed systems. A second stack on site will only be used during plant start-up and there would only be emissions from it for the initial 12 hours or so of operation.


The impact of additional road transport as a result of the new development has been modelled separately and was included in our decision making. Additional road transport will be kept to a minimum as the primary fuel to the power station will be delivered by ship. All other sources contributing to PM10 particulates in the Port Talbot area are accounted for within the measured ambient background which is included within the modelling work.


Further information on the modelling data used, and responses to previous concerns raised by individuals on this issue can be viewed in the decision document which accompanies the permit.


Biomass plants such as Prenergy's Port Talbot power station will play an important role in helping combat climate change if the wood they burn is sourced sustainably. As part of its environmental permit, Prenergy must prove to the Environment Agency that the wood it burns comes from sustainable sources. This new power station will make an important contribution be a big step towards meeting the Government's climate change and renewable energy targets.


Our policy, in line with Government guidance, allows for the permitting of new sites in areas of failing air quality, providing the additional impact of new sites is negligible. Any other approach would prevent any development, however small, in some areas.


The emission limits in the permit ensure that the contribution of

Prenergy to the ambient air quality will be negligible.


Evidence from other industries using bag filters and information on PAH emissions from contaminated wood-burning facilities (which would produce higher levels of polycyclic aromatic hydrocarbons (PAHs) than the clean wood to be used at this site) gives us confidence that Prenergy will be able to meet the limits set for particulates and PAHs. All other limits set are routinely met by combustion units that utilise similar abatement technology to that to be used at the Prenergy plant.


The Prenergy power station will have one main point source emission to air. As stated, there is a second point associated with plant start-up. The enclosed nature of the operation and controls on the storage, handling and movement of wood and ash should ensure that fugitive emissions are minimised. The permit requires continuous monitoring of PM10s in the emissions to air. This will provide us with the relevant information on the PM10 releases from the site.


Regulation of the installation


Our regulatory effort is focussed on ensuring that permitted sites operate within their environmental permits. Where a permit holder does breach the conditions of their permit, or other relevant environmental legislation, then the Environment Agency will take appropriate enforcement action in line with our Enforcement and Prosecution Policy.


Since the permit was issued, we have met with the operator and they have confirmed to us, as well as stating publicly in their own press release, that they are confident of being able to operate within the conditions and limits set in their permit.


Our commitment to improving air quality in the locality


We are currently working closely with Neath Port Talbot County Borough Council, the Welsh Assembly Government and local industry to improve the air quality in Port Talbot. This work has already included an extensive review of all the environmental permits at the nearby integrated steelworks site.


We have spent a great deal of time listening to the views of local people on the Prenergy Plant and the final decision to grant a permit followed extensive public consultation. The consultation included ongoing engagement with a local pressure group throughout the determination process, a public drop-in surgery in July 2009 to answer questions about the plant and consultation under the Public Participation Directive to which local people were invited to submit their views.


12 February 2010