Kemsley Paper Mill (K4) CHP Plant
Queries raised following the issue of the Kemsley Paper Mill (K4) CHP Plant Scoping Opinion
Further to my email below we have looked into your queries and have the following comments. For ease of reference my comments are made under the same headings as in your email.
Risks of Accidents and Disasters
You have asked the Inspectorate to confirm if your proposed approach to assessing the risk of major accidents and disasters during construction and decommissioning set out in your email below is an acceptable one. The approach described was not contained in your Scoping Report and so the Inspectorate did not address this specifically in the Scoping Opinion. The Inspectorate does not consider it appropriate to comment in detail on the scope of an assessment outside of the formal Scoping Opinion process. However, the Applicant is reminded that an Environmental Statement (ES) must include (amongst other things) a description of the likely significant effects and of any features of the Proposed Development or measures envisaged in order to avoid, prevent or reduce and, if possible, offset likely significant adverse effects on the environment. Therefore, if the proposed approach described by the Applicant is sufficient to address the requirements of the EIA Regulations in this regard then it may be regarded as an acceptable one. The Applicant should note that in any event the Inspectorate, on behalf of the Secretary of State, is required to consider the overall adequacy of the information provided with an application for a Development Consent Order. The consideration will include whether the ES is adequate according to the EIA Regulations.
The Inspectorate’s comments contained in the ‘Risk of accidents and disasters’ section of the topic-based scoping table (page 46) in the Scoping Opinion the location of which you have queried refer to points raised at paragraphs 3.3.19 – 3.3.20 of the Scoping Opinion.
It is correct that the Inspectorate did not comment specifically on human health in the Scoping Opinion. The information contained in Table 2.1 of the Scoping Report indicated that matters relating to human health would be scoped in for all phases of the Proposed Development, and that it will be considered under other topics, such as, for example, air quality, ground conditions and noise. The Inspectorate did not feel the need to comment on this approach.
Community, Social and Economic, Land Use and Waste Effects
To clarify, the Inspectorate agreed, in paragraph 3.3.7 of the Scoping Opinion, that these topics do not need to be included in the ES as standalone chapters. However, as you note, the Inspectorate considers that matters relating to waste should be considered within relevant topic chapters as appropriate and in particular where there may be potential for significant effects, such as, for example, in relation to increased traffic.
In relation to your final point, our understanding according to paragraph 1.4.9 of the Scoping Report is that K3 will supply energy in the form of steam to the paper mill; not to K4, the Proposed Development.