Gent Fairhead & Co Limited REGULATION ADDITIONAL INFORMATION

Transcription

1 Gent Fairhead & Co Limited REGULATION ADDITIONAL 19 INFORMATION

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3 December i Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf TABLE OF CONTENTS SECTION PAGE 19.0 TOWN AND COUNTY PLANNING ACT 1990 (AS AMENDED), ENVIRONMENTAL ASSESSMENT REGULATIONS 1999 (AS AMENDED), REGULATION 19 ADDITIONAL INFORMATION Introduction Waste Capacity & Types ercf Waste Throughput ercf and the JMWMS Need for C&I Waste Treatment Markets for Materials from the ercf Supporting Information on the Current C&I Management Capacity Policy Considerations East of England Plan, Addendum Issue ercf Support of the Overall Strategy and Policy Focus C&I Policy Considerations Need for the Pulp Facility Municipal Solid Waste Paper Arisings 2004/ C&I Recovered Paper and Card Waste Paper Composition Extrapolated Data on Potential Paper and Card Feedstock Influence of the Palm Paper Facility Kings Lynn CHP Plant CHP Generating Capacity ercf Operational Power Requirements Connections to the National Grid Dispersion of Emissions and Chimney Stack Height Objective of Additional AQIA Assessment Approach to the Additional AQIA Assessment Short Term (15 minute averaged) SO 2 Assessment Short Term (1 hour averaged) NO 2 Assessment Additional AQIA Assessment Conclusions Disposal of Ash Traffic and Highways Additional Transport Assessment Calculations and Clarifications Predicted ercf Traffic Flows Surface Water Background IOH 124 Greenfield Runoff Rational Method Post ercf Development

4 December ii Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf Storm Water Attenuation Summary of Additional Surface Water Information Ecology Additional Ecological Information Trees Additional Tree Survey The Site The Trees Implications of the Proposed Development Tree Protection Visual impact Design General Layout Listed Buildings The Grade II Listed Pump Woodhouse Farm Cross Section Staff and Visitor Car Park Cultural Heritage Woodhouse Farm Cottage Removal of the Existing Hangar Rights of Way LIST OF TABLES Table 19-1 Table 19-2 Table 19-3 Table 19-4 Table 19-5 Table 19-6 Table 19-7 Table 19-8 Table 19-9 Table Table Summary of the Amount, Type and Source of Waste East of England Plan: Forecasts of annual C&I wastes tonnage to be managed UK and European Production of Recycled Content Graphics and Tissue Paper 2006/07 East of England Plan Forecast C&I Waste Arisings in Essex and Southend ( 000 tonnes) Waste Strategy for England Targets The Composition of Recovered Paper and Card Estimated total recovered paper and card from Commercial and Industrial waste sources based on 2006 figures Estimated total recovered paper and card from Municipal waste sources based on 2006 figures Extrapolated tonnage of non-recovered paper in the 2007 C&I waste stream Estimated Total Recovered Paper and Card from Municipal Waste sources based on 2006 figures Environmental standards used in stack height analysis

5 December iii Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf Table Table Background Concentrations The effect of changing the biogas engine stack height on resultant predicted 15 minute averaged SO 2 concentration Table The effect of changing the CHP chimney height on resultant predicted 15 minute averaged SO 2 concentration Table The effects of changing the emission limit of NO 2 on the maximum PEC Table The effect of changing the biogas engine stack height on resultant predicted 1 hour averaged NO 2 concentration Table The effect of changing the CHP chimney height on resultant predicted 1 hour averaged NO 2 concentration Table Licensed hazardous waste facilities Table Total Base Inflows at Site Access / A120 Junction Table Additional Tree Survey LIST OF FIGURES Figure 3-8A Figure 3-12A Figure 3-14A Figure 3-18A Figure 3-19A Figure 19-1 Figure 19-2 Figure 19-3 Figure 19-4 Figure 19-5 ercf General Arrangement ercf Detailed Cross Sections ercf Upper Lagoon & Wetland Shelf Woodhouse Farm Primary and Secondary Screening ercf General Arrangement Waste Treatment & Process Flows Tree Survey Tree Constraints & Protection Plan Proposed Layout of the ercf & Woodhouse Farm ercf Base Plan APPENDICES Appendix 19-1 Appendix 19-2 Appendix 19-3 Appendix 19-4 Appendix 19-5 Appendix 19-6 Appendix 19-7 Essex County Council, Regulation 19 Request for Additional Information EDF Energy Network Distribution Blackwater Aggregates Expression of Interest Additional TEMPRO/NRTF calculations Predicted ercf Traffic Flows Storm Water Run-Off Calculations RK/PA/03: Landscaping Strategy Access Road and Bradwell Pit North

6 December TOWN AND COUNTY PLANNING ACT 1990 (AS AMENDED), ENVIRONMENTAL ASSESSMENT REGULATIONS 1999 (AS AMENDED), REGULATION 19 ADDITIONAL INFORMATION PLANNING APPLICATION: Development of an integrated Waste Management Facility comprising: Anaerobic digestion plant treating mixed organic waste, producing biogas converted to electricity through biogas generators; Materials Recovery Facility for mixed dry recyclable waste to recover materials e.g. paper, plastic, metals; Mechanical Biological Treatment facility for the treatment of residual municipal and residual commercial and industrial wastes to produce a solid recovered fuel; De-inking and pulping paper recycling facility to reclaim paper; Combined Heat and Power Plant utilising solid recovered fuel to produce electricity, heat and steam; Extraction of minerals to enable buildings to be partially sunken below ground level within the resulting void; Visitor/Education Centre; Extension to existing access road; Provision of offices and vehicle parking; and Associated engineering works and storage tanks LOCATION: Rivenhall Airfield, Coggeshall Road (A120), Braintree, CO5 9DF, OS Grid Reference TL 824:204 APPLICANT: Gent Fairhead & Co Limited, Royal Crescent, LONDON, W11 4SL APPLICATION NO: ESS/37/08/BTE 19.1 Introduction On 26 August 2008, (UK) Ltd, planning agents for Gent Fairhead & Co Limited (GFC), submitted a Planning Application to Essex County Council (ECC) for the construction of an evolution of the Recycling and Composting Facility (ercf) on part of Rivenhall Airfield in Essex. The ercf presents a further development of the design of the original Recycling & Composting Facility (RCF) on the same site, which was resolved to be granted planning permission by Essex County Council s Planning Committee on 30 March Having reviewed the ercf application and consultation responses, on the 24 November 2008 ECC issued a Regulation 19 Request for Additional Information in accordance with the Town and Country Planning Act 1990 (As Amended) and the Environmental Assessment Regulations 1999 (As Amended), referenced DC/CMT/ESS/37/08/BTE. A copy of the letter is presented in Appendix Therefore, the following supplementary and supportive information is provided to address and clarify the points raised by ECC.

7 December Waste Capacity & Types The following information is intended to address and clarify the comments raised by ECC to clarify the amount, type (e.g. Municipal Solid Waste (MSW) i.e. black bag waste and Commercial and Industrial (C&I) waste) or source of the waste to be brought to the Site. A copy of the Regulation 19 Request for additional information is presented within Appendix On 20 May 2008, the ECC Cabinet approved the principles of the OBC for the future management of waste. The assumptions underlying the Reference Project remain consistent with Council policies as documented in the Joint Municipal Waste Management Strategy (JMWMS) and the Essex and Southend Waste Local Plan. The ercf is intended to meet the requirements of the Outline Business Case (OBC) for the Essex Waste Management Partnership Private Finance Initiative and satisfy the requirements of the JMWMS. The amount, type and potential source of the waste to meet the above is presented on Table 19-1 and summarised below: Treatment Technology OBC Total Capacity Requirements (tonnes) Proposed ercf Capacity (tonnes) ercf Surplus Capacity (tonnes) MBT 226, ,000 24,000 AD 71,250 85,000 13,750 MRF 91, ,000 9,000 TOTAL 399, ,000 46,750 In addition to the above, the ercf will incorporate the following waste treatment processes: A Market De-inked Paper Pulp Production Facility (Pulp Facility) to de-ink and recycle paper and card such as newspapers and magazines (combined input capacity of up to 360,000 tonnes per annum (tpa) (i.e. 331,000 tpa of imported waste paper, magazines and card and 29,000 tpa residual paper and card derived from the Materials Recovery Facility (MRF) & Mechanical Biological Treatment (MBT)); and A Combined Heat and Power (CHP) plant to supply energy to the Site and export electricity to the national grid (capable of treating up to 197,000 tpa of solid recovered fuel (SRF) plus paper pulp residues). The CHP will treat the biodried SRF produced by the ercf s MBT, together with other biodried materials that will be imported to the Site from other MBT facilities such as Courtauld Road, Basildon. These MBTs will produce 197,000 tpa of biodried SRF. In addition the ercf s Pulp Facility will produce between 110,000 and 165,000 tpa of pulp process waste sludge, the residues of which will also be treated by the CHP.

8 December Table 19-1: Summary of the Amount, Type and Source of Waste District Collections, RCHWs, C&I, SRF & Paper Import Summary Authority MSW MDR MOW Mixed Paper SRF Braintree Epping Forest (50%) Harlow Uttlesford Chelmsford Colchester Maldon Tendring RCHWs North Essex Eastbound Import from RCHWs Westbound Import from RCHWs C&I Imports Balancing C&I Imports SRF & Paper Imports Mixed Paper & Card Solid Recovered Fuel TOTAL Notes: 1, Reference document: Joint Municipal Waste Management Strategy for Essex (2007 to 2032). Summary of RCHW operations in North Essex MOW MDR MSW Direct to Transfer Station Site Name, Location Green Paper & Card Plastics Landfill Waste Glass Textile & Shoes Cans & Scrap Fridges CRTs Car Batteries Tyres Ceramics Engine Oil Timber Shalford, Braintree Witham, Braintree Ongar, Epping Harlow, Harlow Saffron Waldon, Uttlesford Boreham, Chelmsford S Woodham, Chelmsford Colchester, Colchester West Mersea, Colchester Burnham, Maldon Maldon, Maldon St Osyth, Tendring Dovercourt, Tendring Kirby, Tendring Clacton, Tendring Lawford, Tendring Total Waste Available to ercf Total Import to ercf Note: 1, It is considered that 35% of the MSW from the RCHW will be exported directly to landfill. 2, Reference document: Joint Municipal Waste Management Strategy for Essex (2007 to 2032).

9 December Therefore, should the ercf be successful in securing a PFI contract from ECC, over and above the proposed 331,000 tonnes of waste paper for the Pulp Facility, the ercf will be used to process an additional 46,750 tonnes of C&I waste. However, it should be noted that should the ercf be unsuccessful in securing a PFI contract from ECC, it will be developed to recover, recycle and treat C&I waste ercf Waste Throughput The total capacity of each element of the ercf is presented on Figure 19-1, which shows the balance of material flowing through the various waste recovery, recycling and treatment technologies ercf and the JMWMS The JMWMS identifies that in 2006/07 Essex produced approximately 738,500 tonnes of MSW. The majority of the MSW waste stream comprised household waste, of which 36% was either recycled or composted. Recycling was achieved through source separation at the household and the subsequent kerbside collection of MDR and MOW, in addition to materials collected from bring banks, or local Recycling Centres for Household Waste. The JMWMS recognises that in order for ECC to meet its landfill diversion targets it must significantly improve its recycling and recovery rates. Therefore, the JMWMS has as one its key objectives to achieve high levels of recycling; with an aspiration to achieve 60% recycling of household waste by 2020 (This figure is 10% higher than the target in Waste Strategy for England 2007). The strategy also recognises that this alone will not be enough for ECC to meets its diversion targets. Therefore, in order to deliver an innovative and resource efficient waste management strategy across Essex the JMWMS identifies the need to invest in additional new technologies to treat residual waste and which can extract further value and recyclable materials from the waste stream. The JMWMS identifies that Essex favours composting technologies such as AD for the MOW to produce biogas which can be used to generate 100% renewable electricity. The strategy also identifies the need for new residual waste treatment technologies, and proposes MBT as the preferred technology for processing black bag waste. This will enable the recovery of further material for recycling with the residual fraction used to manufacture SRF that can be used for energy production or sent to landfill. The JMWMS does not itself set out detailed figures for the level of new waste treatment capacity required; instead this is developed in the OBC.

10 December The proposed ercf which has been designed specifically to meet the requirements of both the OBC and JMWMS in relation to the management of wastes in North Essex and incorporates the preferred technologies identified in JMWMS. Therefore, the ercf incorporates environmental and technological features that reflect the need for local recycling and waste treatment facilities by incorporating the following waste treatment processes: A MRF to sort recyclable materials collected by the Waste Collection Authorities (input capacity of 100,000 tpa); An Anaerobic Digestion (AD) plant to generate energy from mixed organic wastes (input capacity of 85,000 tpa); A MBT to treat a combination of mixed residual MSW (i.e. black bag wastes), and/or C&I waste (capable of treating up to 250,000 tpa); A Pulp Facility to de-ink and recycle paper and card such as newspapers and magazines (combined input capacity of up to 360,000 tpa (i.e. 331,000 tpa of imported waste paper, magazines and card and 29,000 tpa residual paper and card derived from the MRF & MBT)); and A CHP plant to supply energy to the Site and export 33 MW of electricity to the national grid (capable of treating up to 197,000 tpa of SRF plus paper pulp residues). It should be noted that the technologies proposed for the treatment of MSW and/or C&I waste match those proposed by the JMWMS in order to recover the maximum recyclable yield from the waste stream, produce compost, manufacture a fuel and produce electricity from biogas and fuel treatment Need for C&I Waste Treatment The East of England Plan forecasts that that C&I waste will grow by between 2% and 3% per annum in line with economic growth over the period to 2020; although these forecasts were based on assumptions that predate the current economic downturn. There is now an expectation that the growth in C&I waste will slow. On the basis of the Waste Strategy for 2007, levels of C&I waste landfilled are expected to fall by 20% by 2010 compared to The East of England Regional Assembly has commissioned a further study of C&I waste arisings in the East of England which is due to be published in January Appendix C of the East of England Plan (May 2008) sets out the forecasts of the MSW, C&I and imported wastes to be managed by each waste disposal authority in the East of England. The forecasts for C&I wastes for Essex and for the East of England as a whole are summarised in summarised in Table 19-2:

11 December Table 19-2: East of England Plan: Forecasts of annual C&I wastes tonnage to be managed Year Essex and Southend 1,592,000 1,808,000 2,076,000 2,420,000 East of England 7,081,000 8,040,000 9,237,000 10,763,000 As far as future C&I waste treatment and disposal capacity is concerned this has been the subject of a comprehensive study by ERM: Waste Arisings, Capacity and Future Requirements Study - Final Report published in February The ERM report considers waste arisings and management capacity for C&I wastes and other wastes streams. It identifies from the outset that the future capacity requirements are heavily dependent upon the growth assumptions. However, the report does not attempt to define future capacity on the basis of any one projected growth scenario, but instead offers best and worse case scenario forecasted capacity requirements for each type of waste management capacity. The best case is based upon decoupling waste production from economic growth and growth in population and the number of households; whilst the worst case is based on a hypothesised credible maximum level to waste growth, if waste reduction measures are not successfully brought about in practice. The report identifies that the best case or lower bound is unlikely in the immediate future, and that waste production will generally continue to grow in the short to medium term. However, it also states that the lower bound is potentially achievable in the medium to long term, if MSW reduction measures are pursued, and if businesses respond to waste reduction drivers. For the assumed levels of growth, the ERM report highlights the anticipated waste management capacity gap in Essex over the next 15 years, i.e. up to Forecasts of waste arisings for the five main waste streams, namely: MSW, C&I, C&D, Hazardous and Agricultural were carried out, against which waste management capacity estimates were compared. The report divides the capacity assessment into Recovery and Treatment, meaning waste treatment and energy recovery excluding recycling and composting, and recycling and composting. The results of these comparisons show that Essex lacks capacity for different types of Recovery and Treatment facilities to different degrees. The report considers MSW and C&I waste management capacity together, and identifies that the Recovery and Treatment capacity is below the worst case estimates. By 2010, an additional 200,000 tonnes of additional capacity is required rising to 610,000 tonnes by However, the difference between the best and the worst case scenario in the amount of extra capacity required by 2021 is 300,000 tonnes. The best case growth scenarios show that on top of the 150,000 tonnes currently available in Essex, a further 300,000 tonnes of Recovery and Treatment capacity is required.

12 December Under the worst case scenario, assuming the RSS waste projections (which are similar to ERM s worst case), C&I wastes would represent approximately 69% of the total waste stream. Therefore, considering the additional capacity requirements identified within the ERM report, this could equate to 420,000 tonnes of additional C&I Recovery and Treatment capacity. The proposed ercf will provide 250,000 tonnes of primary treatment and recovery capacity in the form of the MBT. Therefore, even allowing for the development of the ercf s MBT Essex could be required to source an additional 170,000 tonnes of Recovery and Treatment capacity. Furthermore, it is possible that an additional 360,000 tonnes of Recovery and Treatment capacity would be required by For recycling and composting ERM identify that the amount of capacity that is required over and above the current level is 1½ Million tpa by 2021 based on the requirement for both MSW and C&I waste under the worst case scenario. The amount required by 2010 is 785,000 tpa. The ERM report stresses that the average amount of recovery and recycling carried out at ECC s existing network of Waste Transfer Stations (WTSs) is a factor affecting the of new capacity requirements. For the purposes of the assessment ERM considered this to be 20%. Should the recovery and recycling rate at the WTSs rise above 20%, the requirement for further Recovery and Treatment capacity declines. However, when considering an estimated 40% recovery and recycling rate at the WTSs, the Recovery and Treatment capacity required drops to 515,000 tonnes by 2010 and approximately 1¼ Million tonnes by With best case arisings, the additional recycling and composting capacity required is 680,500 tpa over and above the existing capacity. The proposed ercf (excluding the Pulp Facility) will provide 185,000 tonnes of recycling and composting capacity (i.e. 100,000 tonnes MRF capacity and 85,000 of AD capacity). Therefore, considering the waste growth predictions for 2021, over and above the recovery, recycling and treatment capacity of the ercf, ECC could require a further 1 Million tonnes of additional C&I treatment capacity under the worst case scenario. Clearly, the level of provision proposed by the ercf would only go part of the way to meeting the forecast capacity gap for Essex s C&I recycling and composting infrastructure. The ercf will include a Market De-inked Paper Pulp Production Facility (Pulp Facility) to de-ink and recycle paper and card such as newspapers and magazines (combined input capacity of up to 360,000 tpa (i.e. 331,000 tpa of imported waste paper, magazines and card and 29,000 tpa residual paper and card derived from the MRF & MBT)). As presented within Chapter 7 of the Planning Application Supporting Statement, as a minimum the waste paper feedstock will be sourced regionally from the East of England. Therefore it is inappropriate to consider that the Pulp Facility would provide further C&I treatment capacity. Based on assumptions relating to the paper and card content of the C&I waste stream, it is considered that paper and card makes up approximately 12.72% of C&I. Therefore, if it is

13 December assumed that the figures for existing and additional future C&I waste capacity are reduced by this amount, whilst this would reduce the worst case requirement for additional C&I waste recycling and recovery capacity to approximately 1.3 Million tonnes, which is still significantly in excess of that proposed at Rivenhall. It also however, clear that the proposed Pulp Facility will provide a surplus capacity for waste paper recycling in Essex. In 2006 it was estimated that the total quantity of waste paper arising in Essex was 230,000 tpa or 290,000 tonnes including the recovered paper and card element of MSW. These figures exclude an estimated 140,000 tonnes of paper and card that is not recovered. Details of the waste paper feedstock and the need for the Pulp Facility are presented in Section Markets for Materials from the ercf The identification of suitable markets for the recovered and recycled materials output from the ercf is a contractual matter. Therefore, it is not possible to provide specific details, on the outlets for the various material and outputs from the ercf, other than to say that these will sold into established markets. The main residual output from the MBT and MRF will provide the SRF for the CHP plant that will generate the power, heat and steam required to operate the Pulp Facility. Electricity generated by the ercf will be exported into the National Grid. The effects of the recent collapse in demand for recycled products, particularly in export markets, have demonstrated the vulnerability of local authorities' recycling plans in the Eastern Region and elsewhere in the UK to the shortage of processing capacity. On 5 December 2008 the Environment Agency reported that, during the period 14 November-5 December 2008, 56 local authorities applied to stockpile waste that could no longer profitably be recycled. As a consequence, local authorities in the Eastern Region and elsewhere have stopped collecting some recycled products. Investment in facilities for processing recycled products into raw materials for manufacturers in the UK is the primary means by which the risk of such events being repeated is mitigated. In the words of the Chairman of the Environment Agency (Lord Smith in a speech to the Aldersgate Group, 4 December, 2008): "..in the long-term, the United Kingdom needs to have a more resilient domestic market for recyclable materials. We need to treat the security of materials and hard commodities the same way we treat the security of food and energy. Often, an economic downturn is the best time to identify investment opportunities. What the current market conditions do show us is that there is a gap in the market to deal with recyclable materials here is the UK.

14 December There is a legitimate export market for recyclable materials but it needs to be complimented with a resilient domestic recycling industry. Lord Smith will urge local authorities and the waste sector to embrace a three-point plan to protect recycling: i. In the short-term - well-sorted, top-quality recyclable materials will be more likely to maintain a market; ii. iii. In the medium-term - there is the need to identify and invest in new or innovative uses for our materials to divert even more waste from landfill; and In the long-term - we need to look at investing in more infrastructure to treat recyclable materials here in the UK, to avoid dependency on the export market." The particular vulnerability of paper recycling in the Eastern Region and elsewhere in the UK arising from the shortage of domestic reprocessing capacity makes the need for the ercf not only compelling but urgent. Without such facilities, all recycling in the Eastern Region is jeopardised in each downturn in overseas markets. Therefore, it is considered that this application is fully in conformity with Policy WM3 in the East of England Plan. Details of the market for proposed high grade pulp from the Pulp Facility are set out in Section of the Planning Application Supporting Statement together with details of the Potential UK and European Markets for MDIP (Section of the Planning Application Supporting Statement. These are presented below: Market Need for the Proposed High Grade Pulp From a combined input of 360,000 tpa of waste paper and card recovered from MSW (i.e. black bag waste) and C&I wastes the pulp facility will produce the following Grade 3 recycled MDIP for use in new paper production: 216,000 tpa to 226,800 tpa for tissue MDIP; and 198,000 tpa to 216,000 tpa for graphics MDIP. According to WRAP, MDIP is mainly used as a substitute for bleached hardwood pulp (BHP), and bleached eucalyptus Kraft pulp (BEK). The potential users of MDIP are those graphics mills and tissue mills that manufacture products from recycled paper fibres. The Pulp Facility will be capable of producing MDIP products ranging in quality from tissue to graphics. These quality requirements vary significantly and are summarised as follows: Graphics pulp generally needs to have a very high level of brightness and a high level of cleanliness; and Tissue pulp does not need to have such high levels of brightness and cleanliness, but needs to have low levels of freeness and ash.

15 December To achieve higher levels of brightness and cleanliness, as required for graphics pulp, the feedstock will require more processing. It is intended that the MDIP produced at the Pulp Facility will be of a high enough quality to be sold, as a replacement for BHP and BEK, to graphics and tissue mills in the UK, Europe and, if appropriate, worldwide. In summary, there are: 8 tissue mills in the UK with a combined annual capacity of approximately 500,000 tpa; 74 tissue mills in the rest of Europe with a combined capacity of just under 3 million tpa; 1 graphics mills in the UK with a capacity of approximately 35,000 tpa; and 25 graphics mills in the rest of Europe with an annual capacity of 1.5 million tpa. The combined annual capacity of the tissue and graphics mills that process recovered graphics and tissue paper in the UK and Europe is just under 5 Million tpa. Table 19-3 below shows the quantities of virgin and recycled fibre materials used in the manufacture of graphics and tissue paper in the UK and Europe. These paper mills were selected because they all use a proportion of recovered paper/fibres in their products; hence, it was assumed that they are likely to have a greater demand for the MDIP. Table 19-3: UK and European Production of Recycled Content Graphics and Tissue Paper 2006/07 Product Location No of Mills Feedstock tpa Totals Virgin Fibre Recycled Fibre (BHP and BEK)* Graphics UK 1 5,000 30,000 35,000 Graphics Rest of Europe , ,500 1,540,000 Total Graphics Use 549,500 1,025,500 1,575,000 Tissue UK 8 111, , ,000 Tissue Rest of Europe 74 1,319,000 1,587,900 2,906,400 Total Tissue Use 1,430,500 1,980,400 3,410,900 * This column represents the total annual quantity of Virgin Fibre (BHP and BEK) feedstock purchased by UK & European paper mills in 2006/07. A proportion of this material could be substituted with high quality MDIP. Between 198,000 tpa to 216,000 tpa of graphics pulp and 216,000 tpa to 226,800 tpa of tissue pulp potentially produced at the Pulp Facility could provide approximately 14% or 7% of the total combined UK and EU mill feedstocks Supporting Information on the Current C&I Management Capacity An assessment of current C&I waste arisings are based on the Forecasts of Wastes to be managed in Essex set out in Appendix C of the East of England Plan (May 2008) and included in Table 4 below.

16 December Table 19-4: East of England Plan Forecast C&I Waste Arisings in Essex and Southend ( 000 tonnes) Essex and Southend The latest estimates of current C&I waste management capacity in Essex are set out in ERM the report Waste Arisings, Capacity and Future Requirements Study Final Report published in February The report identifies that in February 2007 there was a total of 502,307 tonnes of MSW and C&I waste recycling and composting capacity (based on 20% of WTS capacity is used for recycling). If this figure is disaggregated in line with the percentage of total wastes to manage as set out in Appendix C of the East of England Plan, i.e %, then the total C&I waste recycling and composting capacity would be 278,228 tonnes. The corresponding figures for recovery and treatment capacity are 157,825 tonnes total disaggregated MSW & C&I capacity, and 87,419 tonnes of C&I capacity Policy Considerations East of England Plan, Addendum Issue Although no explicit reference is made to the Addendum issued at the same time that the East of England Plan was published, (which corrects what is assumed to be only a typographical error), and because the proposed ercf has been designed to support the OBC and JMWMS, the lack of reference to the Addendum does not affect the need case for the ercf ercf Support of the Overall Strategy and Policy Focus The ercf has been principally designed and sized to support ECC s OBC and JMWMS. The JMWMS seeks to deliver sustainable waste management in Essex, in line with the objectives of Waste Strategy for England This includes meeting the landfill diversion targets dictated by the Landfill Allowance Trading Scheme ( LATS ), and meeting targets for recycling and recovery. This necessitates the development of a new network of waste facilities. The Essex Waste Management Partnership PFI aims to deliver this new network in relation to the management of municipal waste. The Reference Project identified within the OBC has been designed to meet the objectives of the Councils Strategies, and will, when combined with the Partnership s interim LATS management strategy, meet or exceed Essex and Southend s LATS targets from 2008 onwards. In so far as the proposed ercf seeks to deliver a facility that meets the specification of the Reference Project for North Essex it meets the waste management performance objectives of the Councils Strategies by ensuring compliance with the LATS, the European Union Landfill Directive and associated national recycling legislation.

17 December The development of the ercf will enable the implementation of the objectives of the JMWMS in relation to North Essex in that it will: Reduce and reuse the amount of waste produced; Enable ECC to meet and exceed Waste Strategy for England 2007 recycling, composting, recovery and reduction targets (Table 19-5) with the aspiration of attaining 60% recycling and composting of household waste by 2020; Provide an innovative disposal solution based on MBT technology to assist in diverting Biodegradable Municipal Waste (BMW) from landfill and to recover more value from residual waste; and Provide for the use of biowaste treatment for source-segregated organic waste from which renewable energy can be produced. Table 19-5: Waste Strategy for England Targets Source: OBC for the Essex Waste Management Partnership PFI (April 2008) - Table C&I Policy Considerations The Waste Strategy for England 2007 set out that one of the Government s key aspirations is reduce the amount of C&I waste going to landfill. It envisages that levels of C&I waste landfilled are expected to fall by 20% by 2010 compared to Policy WM2 of the East of England Plan (May 2008) seeks to take forward the aspirations of the Waste Strategy for England 2007 at a regional level in relation to the future management of C&I wastes. It states that challenging but achievable targets should be adopted not only by all local authorities but also by commercial waste producers to minimise waste and provide the basis for implementing the overall aim of recycling, composting and recovering value from waste. The objectives are to secure inter alia the recovery of 72% of C&I waste by 2010 and 75% by On the basis of the figures for forecast C&I waste arisings set out in Appendix C of the RSS this translates in to 1,265,000 tonnes by 2010 and 1,506,000 by 2015 which is substantially in excess of the existing levels of C&I waste recycling and composting, and recovery and treatment capacity identified by ERM (following a comprehensive study) within the Waste Arisings, Capacity and Future Requirements Study - Final Report published in February The East of England Plan anticipates that C&I waste will continue to grow by between 2% and 3% per annum in line with economic growth, although this forecast predated the current economic downturn. Forecasts for the growth in C&I waste arisings in Essex are included in the ERM s Waste Arisings, Capacity and Future Requirements Study Final Report published in February

18 December Whilst this provides an assessment of future capacity requirements on the basis of best and worst case growth scenarios, it anticipates that there is likely to be need for significant additional C&I waste management capacity over the period to 2021 (as detailed above), which would in part be met by the proposed ercf, whether only in relation to the Pulp Facility, or in relation to the ercf as a whole (i.e. as a merchant facility for C&I wastes). Consequently, whether the proposed ercf is developed in response to the Essex Waste Management Partnership PFI, with the main element of C&I wastes being managed and processed through the Pulp Facility or whether it is developed wholly as merchant facility for C&I wastes; it will have important part to play in the provision of additional C&I waste management capacity, in relation to achieving the diversion target for C&I wastes set out in the Waste Strategy for England 2007, and in the securing the proposed levels of recovery that the RSS seeks to achieve Need for the Pulp Facility The following information is intended to address and clarify the comments raised by ECC to clarify the availability of locally sourced feedstock for the Pulp Facility. A copy of the Regulation 19 Request for additional information is presented within Appendix Municipal Solid Waste Paper Arisings 2004/05 To calculate the proportion of paper and card within the MSW waste stream, data from the 2004/05 MSW arisings from the Essex Draft Joint Municipal Waste Management Strategy (DJMWMS) was used, and combined this with assumptions regarding the composition of paper and card recovered from MSW taken from the DEFRA Waste Strategy The following DEFRA assumptions were applied to the Municipal paper and card arisings: 18% of the total MSW arisings was paper and card; 30% of the MSW Paper and card was source separate kerbside (SSKS) materials; 10% of the total MSW paper and card was collected as co-mingled kerbside (CMKS) materials; 3% of the total MSW paper and card was collected from Household Waste Recycling Centres (HWRC); and The remaining 57% was not recovered for recycling C&I Recovered Paper and Card The C&I waste arisings were derived from the Environment Agency s C&I Waste Survey 2002/03 and the DEFRA Waste and Recycling Key Facts 2006/07, as follows: Commercial waste: 44% of the total C & I waste collected was commercial waste; and 20% of commercial waste is paper and card; and

19 December Industrial waste: 56% of the total C & I waste was industrial waste; and 7% was paper and card Waste Paper Composition To establish the quantity of suitable feedstock for the proposed Pulp Facility, Golder has calculated the annual tonnage of each grade of paper that was recovered during This was achieved by applying the composition data presented in Table 19-6 to the total recovered MSW and C&I paper and card presented above. Table 19-6: The Composition of Recovered Paper and Card Material Type % Newsprint 18 Magazines 10 Graphics 20 Card packaging 44 Mixed paper and card 8 Total Recovered Paper 100 This composition data was taken from the Recovered Paper Data report, 2001, produced by the Food and Agriculture Organisation of the United Nations (FAO) and the Confederation of European Paper Industries (CEPI) Extrapolated Data on Potential Paper and Card Feedstock Based on the assumptions outlined above the following figures have been compiled from extrapolated data on potential paper and card sources based on published data of recent estimates paper wastes arisings and MSW and C&I waste arisings. Tables 19-7 and 19-8 contain estimated tonnages of paper and card wastes from MSW, and C&I waste arisings are presented for the UK, East of England, Essex and London. The breakdown of paper types has been extrapolated from estimated paper compositions of MSW and C&I wastes from the following data sources: Essex Draft Joint Municipal Waste Management Strategy (2005 to 2030); DEFRA Waste Strategy 2007; Environment Agency s Commercial & Industrial Waste Survey 2002/03; DEFRA Waste and Recycling Key Facts 2006/07; and Recovered Paper Data report, 2001, produced by the Food and Agriculture Organisation of the United Nations (FAO) and the Confederation of European Paper Industries (CEPI).

20 December Table 19-7: Estimated total recovered paper and card from C&I waste sources based on 2006 figures Assumed composition Total Recovered Paper and Card 2006 (tonnes) % UK EOE Essex London Newsprint , ,000 41, ,000 Magazines ,000 85,000 23, ,000 Printing and writing 20 1,100, ,000 46, ,000 Packaging 44 2,420, , , ,000 Mixed paper and board 2 110,000 17,000 4,600 26,000 Mixed paper 6 330,000 51,000 13,800 78,000 5,500, , ,000 1,300,000 Table 19-8: Estimated total recovered paper and card from Municipal waste sources based on 2006 figures Assumed composition Total Recovered Paper and Card 2006 (tonnes) % UK EOE Essex London Newsprint ,000 39,600 10,800 63,000 Magazines ,000 22,000 6,000 35,000 Printing and writing ,000 44,000 12,000 70,000 Packaging ,000 96,800 26, ,000 Mixed paper and board 4 84,000 8,800 2,400 14,000 Mixed paper 4 126,000 13,200 3,600 21,000 2,100, ,000 60, ,000 In addition to the figures for recovered paper, the quantities presented in Table 19-9 represent the extrapolated figures for paper wastes identified in the C&I waste stream that indicate the potential for increased recovery of paper in the C&I waste stream. Table 19-9: Extrapolated tonnage of non-recovered paper in the 2007 C&I waste stream Total C&I Paper not recovered 2007 (tonnes), i.e. landfilled, exported or burnt Assumed Proportion % UK EOE Essex London Newsprint 18 1,062,000 91,800 25, ,200 Magazines ,000 51,000 14, ,000 Printing and writing 20 1,180, ,000 28, ,000 Packaging 44 2,596, ,400 61, ,600 Mixed paper 2 118,000 10,200 2,800 24,800 mixed board 6 354,000 30,600 8,400 74,400 5,900, , ,000 1,240,000 Based on the 2006 figures further revised estimates of the preferred feedstock have been compiled (comprising magazines, printing and writing paper and mixed paper) for paper and card recovered from the MSW and C&I wastes collected in Essex and the East of England. These suggest a total potential feedstock of 400,000 tonnes. Whilst these figure are lower than originally indicated in the Planning Application Supporting Statement, growth is in fact anticipated to 25% over the period to 2015, thereby still giving a total quantity of graphics and magazines of 600,000 tonnes by 2015.

21 December Table 19-10: East of England Region - Estimated Quantity of available Feedstock 2005/06 Region Total Quantity of Recovered Graphics and Magazines (tpa) Essex 100,000 East of England (excluding Essex arisings) 300, ,000 These figures indicate that the potential feedstock capacity within Essex and East of England may provide a significant proportion, if not all, of recovered paper source for Rivenhall Airfield Influence of the Palm Paper Facility Kings Lynn The ERM report on the Review of the Environmental Statement for the Rivenhall Airfield Evolution of the Recycling and Composting Facility which was prepared on behalf of Braintree District Council, identifies that a key issue regarding the need case for the proposed ercf is the influence of the new Palm Paper facility. It identifies that a new Newsprint Mill is being constructed by Palm Paper Limited outside Kings Lynn. This is due to be operational in This Palm Paper facility will have a capacity of 500,000 tpa and will produce up to 400,000 tpa of paper. These quantities are likely to have a significant impact on the amount of available feed stock and on the highly variable potential paper pulp market. ERM identify that when compared to the predicted estimates of the quantities available at 2015 for the East of England Region (Table PASS-7 of the Supporting Statement 2008), only 100,000 tonnes would remain available. This is considerably lower than the 331,000 tonnes per annum capacity expected at the ercf Pulp Facility. The extrapolated data shown in the Tables 19-7 to indicate that recovered paper feedstock capacity is available from Essex and the East of England. Furthermore, it could be supplemented by some of the anticipated recovered paper feedstock capacity from the London area. The new Kings Lynn facility does not have the same advantages of proximity and transport links to London as Rivenhall (accessed via M11/A120), and therefore the ercf would be a preferable option for utilising some of the London recovered paper capacity. The Kings Lynn facility is better position to serve the recovered paper markets of the East Midlands (via the A47 and A17) and Northern Home Counties, (via the A10). In addition, it should be noted that Palm Paper facility at Kings Lynn is designed to produce a different quality of paper pulp than that proposed by the ercf. Kings Lynn will produce newsprint paper, whereas the ercf is designed to produce both high quality graphics and tissue paper grade pulps. The difference in pulp grade will mean that the Palm Paper facility and the ercf will have different quality requirements for their respective feedstocks, i.e. the Palm Paper Facility will source a newsprint and packaging feedstock. In 2006 the availability of newsprint and packaging across the East England was of the order of 660,000 tonnes from the C&I and MSW waste streams. Therefore it is unlikely the Palm Paper facility in King Lynn would divert most the preferred feedstock from ercf.

22 December It should also be noted that paper is a commodity. Therefore, ultimately the quantity and quantity of paper available to the ercf will be dependent on market prices. Because MDIP is able to command a higher price than newsprint the proposed ercf will be in a position to offer competitive prices for the supply of paper and card; thereby enabling it to compete more effectively in securing supplies CHP Plant The CHP will treat the biodried SRF produced by the ercf s MBT, together with other biodried materials that will be imported to the Site from other MBT facilities such as Courtauld Road, Basildon. These MBTs will produce 197,000 tpa of biodried SRF. In addition the ercf s Pulp Facility will produce between 110,000 and 165,000 tpa of pulp process waste sludge, the residues of which will also be treated by the CHP. The calorific value (CV) of SRF is known to be of the order of 15 MJ/kg to 17 MJ/kg from existing operational facilities. However, the CV of the pulp process waste sludge will be dependant upon the water, fibre and inert material content, following the paper pulping process and proposed dewatering and steam drying operations. SRF delivered to the Site will be blended with SRF manufactured at the ercf and stored in a bunker. High technology furnaces with water cooled grates will be used in the CHP process to treat and recover energy from the biodried SRF. Water cooled grates are the state of the art technology for complex high calorific fuels such as SRF. The performance, efficiency and operational record of furnaces with water cooled grate technology is more favourable than other CHP processes, such as fluidised beds, which are more sensitive to changes in the quality of the SRF. Water cooled grates would offer a furnace technology capable of producing a consistent and reliable supply of electricity, heat and steam from an SRF which may vary in composition. This state of the art furnace and water cooled grate technology has recently been selected for the CHP facility which uses the SRF supplied by the Greater Manchester area CHP Generating Capacity To assess the overall generating capacity of the CHP it is considered that the CV of blended SRF and pulp process waste sludge would be in the range 12 MJ/kg (minimum) to 20 MJ/kg (maximum). This range has been confirmed by technologists working within the European waste industry as appropriate, namely Keppel Seghers and CNIM. The Nominal Working Point of the CHP plant is indicated on the Combustion Diagram (presented below). This illustrates the thermal envelope at which the CHP plant will operate. Therefore, if the CHP is fuelled at a rate of 45 tonnes per hour of blended SRF and pulp process waste sludge with a CV of 16 MJ/kg, it has the capacity of producing 204 MW of Thermal Energy (MWTh).

23 December The Pulp Facility is an integral part or the ercf and will take 60 tonnes per hour of steam at 12 bar as a take off from the main CHP turbine which will produce 46 MW of electricity. It should be noted that the parasitic load of the CHP plant is considered to be 6 MW, i.e. the power required to drive and operate the CHP plant. Therefore, the ercf will have a Declared Net Capacity of 40 MW. In addition to the Declare Net Capacity 40 MW from the CHP plant, a further 2 to 3 MW will be produced by the AD biogas engines. Therefore, it is anticipated that the operation of the ercf will produce a maximum electrical output of up to 43 MW under normal operating conditions ercf Operational Power Requirements The ercf scheme will comprise the following elements: A MRF for 100,000 tpa of mixed dry recyclables for the recovery of recyclable materials such as paper, card, plastic, metals and fine sand and gravels from local householders and Civic Amenity 1 sites; AD for 85,000 tpa Mixed Organic Waste (MOW) from kitchen and green waste collections from local householders and Civic Amenity sites; MBT for 226,000 tpa residual MSW wastes (i.e. black bag wastes) and/or C&I waste; A Pulp Facility for up to 360,000 tpa of reclaimed paper; CHP for 197,000 tpa SRF, plus paper pulp residues; and The redevelopment of Woodhouse Farm, which will be used as an Education Centre and associated car and coach parking for the public. 1 Household Waste Recycling Centre (HWRC)

24 December Electricity will be required to operate the above. The power consumption of each ercf process is presented below, and should be considered when assessing the net available power available for export into the National Grid: The above indicates that the net available power for export to the National Grid from the ercf will be 20.9 MW Connections to the National Grid With reference to the proposed connection of the ercf to the National Grid, EDF has confirmed the following: In accordance with the Electricity Act 1989, the Utilities Act 2000, and other relevant Statutes, EDF Energy as a licensed Distribution Network Operator, is obliged to provide a connection to its electricity distribution network for the transmission of electrical power to or from the customers premises. This connection would be provided at the most economic cost to the customer. Large capacity connections requiring system reinforcement and/or extension would potentially be more expensive than simple schemes and be likely to take longer to provide. Therefore, it is it is most likely that the grid connection point will be at the transformer station just west of the Coggeshall/Kelvedon road, which was known to be suitable for a connection of MW of generating capacity in It should be noted that the export of electricity from the Site to the transformer station at that time was potentially 22 MW. It is therefore anticipated that transformer station will be capable of serving the ercf subject to network upgrade, protection and strengthening works. In the event that the electrical network survey indicates an alternative Grid connection point, then an alternative route along the access road or across open country may be necessary. The

25 December landowner GFC has been made aware of this possibility and has agreed to co-operate as necessary in providing wayleaves for the connection. EDF also has CPO powers if needed to make the connection. Details of the local and regional distribution network are presented in Appendix Dispersion of Emissions and Chimney Stack Height Within the Air Quality Impact Assessment Report (AQIA) a limited stack height analysis was performed using the short term (15 minute averaged) concentration of SO 2. This was carried out because levels of SO 2 were close to the Environmental Assessment Limits (EAL). However, it should be noted that in completing the assessment no emissions abatement techniques were considered. Therefore the predicted emissions represented the most reasonable worst case i.e. a CHP stack of 35 m and a biogas engine stack of 22 m would be sufficient to reduce the 15 minute SO 2 concentration below the relevant EAL of 266 μg/m 3, whilst considering the potential visual impact of the stacks on the surrounding environment. The AQIA has demonstrated that the ercf could be developed with no breaches of the relevant EALs; however, to allow the Waste Planning Authority to consider other developments close to or adjacent to the Site, i.e. the new A120, further AQIA assessments and analyses has been carried out to reduce emissions from the ercf further Objective of Additional AQIA Assessment In response to ECC s Regulation 19 Request for Additional Information (Appendix 19-1), further stack height sensitivity analysis has been undertaken. As the proposed Site contains two stacks, namely: that of the CHP and the biogas engines; consideration has been given to both sources of emissions to air. This analysis aimed to highlight the potential optimum stack heights at the Site. The assessment has concentrated on two results: 1. The effect of increasing the two different stack heights on the resultant maximum predicted 15 minutes Sulphur Dioxide (SO 2 ) concentrations which is the result closest to the relevant EAL; and 2. The effects using a more conservative emission rate for short term (1 hour) Nitrogen Dioxide (NO 2 ) from the CHP i.e. to use a short term NO 2 emission concentration of 200 mg/nm 3 (previously only 50% of short term NOx had been assumed to be NO 2, in this reassessment all NOx is assumed to be NO 2 ).

26 December Approach to the Additional AQIA Assessment This assessment is based on the use of the AERMOD model built for the ercf. The model uses meteorological data from Stansted Airport and simulates the effects of terrain and buildings on the resultant dispersion of pollutants. The weather station at London Stansted Airport was chosen as the closest location with hourly sequential readings of the parameters necessary to undertake dispersion modelling including: sensible heat flux, friction velocity, vertical potential temperature gradient, convective and mechanical mixing height. The quality and quantity of information from Stansted Airport accounts for changes in wind direction across the Site and makes allowances for times when the wind direction is towards Silver End, Cressing, Braintree, Bradwell, Pattiswick, Coggeshall, Feering, Kelvedon, Rivenhall and Witham. It should be noted that the weather station allows the AQIA assessment to present the most reasonable worst case scenario based on detailed scientific meteorological conditions. The ercf will be construct below ground to minimise its visual impact. The CHP will extend 35 m above existing ground, however it should be noted that the total length of the chimney will be approximately 50 m, i.e. 35 m above ground level plus 15 m below ground level. With reference to comments made by the Environment Agency relating to the design of other similar CHP facilities, the above clarifies that the overall design of the ercf CHP is very similar to other facilities, albeit a proportion of the ercf is hidden from view and constructed below ground level. The original AQIA assessment aimed to balance environmental issues related to the height of the CHP chimney, its emissions and impact on the surrounding environment. A detailed account of the parameters used to build these models and the modelling software is provided within the main AQIA. For the purpose of this additional assessment, the two pollutants which have been taken into consideration are NO 2 and SO 2. The relevant EALs for these pollutants are detailed in Table The short term (1 hour average) NO 2 and short term (15 minute averaged) SO 2 predicted concentrations were deemed to be closest i.e. just below, the required relevant Environmental Assessment Limit.

27 December Table 19-11: Environmental standards used in stack height analysis Combustion Emissions Long Term (Annual) Environmental Standard (μg/m 3 ) Nitrogen Dioxide (1) 40 Environmental Standard (μg/m 3 ) Short Term 200 (Hourly mean, exceeded no more than 18 times per year) 266 (15 minute mean, exceeded no more than 35 times per year) Assessed %iles Assessed Period hour minutes Sulphur Dioxide (Hourly mean, exceeded no more than 24 times per year) hour 125 (24 hour mean, exceeded no more than 3 times per year) hour These derived EALs (or Environmental Quality Standards (EQSs)) are conservative. They are designed to ensure that compliance with the EAL (or EQS) assessment criteria in the H1 guidance (Environment Agency 2003) so that no significant health risk and no additional health risk assessment is required beyond this exposure assessment. The predicted concentrations of gases have been assessed against the relevant EAL (or EQS) at the appropriate averaging period, i.e. 1 hour and 24 hour averages. Where the EAL (or EQS) has a number of exceedances that are allowed, results were calculated at the appropriate percentile. For example, the hourly average NO 2 air quality objective states that the standard should be exceeded no more than 18 times per year, so the modelled impact of the 19 th highest hour is calculated, which equates to the %ile of hourly meteorological data. Background air quality concentrations in the vicinity of the Site have been obtained from the National Environmental Technology Centre (NETCEN, data available at Data for the closest available grid reference for the Site (TL near Woodhouse Farm; the NETCEN maps of estimated background annual mean air pollutant concentrations are on a 1 km x 1 km grid resolution) under the Braintree District Council was used. Generating greater headroom below the relevant EALs would allow for higher background concentrations in the future should additional developments in the area take place, i.e. if the new A120 were proposed adjacent to the Site. The background concentrations were extrapolated using the background calculator available from NETCEN. Background concentrations for NO 2 were extrapolated to 2008, which is more conservative than extrapolating into the future because concentrations are predicted to decrease in the future. SO 2 backgrounds were taken to be the 2001 annual mean as no extrapolation tool was available. The background data used in this assessment are presented in Table

28 December Table 19-12: Background Concentrations Background Air Quality Concentrations Combustion and Surface Background Concentration (µg/m 3 ) Source NO NETCEN Background extrapolated to 2008 SO NETCEN Background no extrapolation Notes: 1. The background data is from the NETCEN website for , for 2004 and 2001; and 2. Background data are for the long-term emissions, for short- term assessment these values are doubled Short Term (15 minute averaged) SO 2 Assessment The results of the AQIA indicated that a 22 m engine stack and a 35 m CHP chimney would result in a Predicted Environmental Concentration (PEC) of approximately 260 μg/m 3, which is below the relevant EAL of 266 μg/m 3. In order to investigate how the PEC could be further reduced by changing the two different stack heights, the CHP chimney and biogas engine stack height parameters have been varied one at a time. Table illustrates the effects of changing the biogas engine stack height whilst keeping the CHP chimney at 35 m; and Table illustrates the effects of changing the CHP chimney height whilst maintaining the biogas engine stack at 22 m. For each of the different chimney and stack heights, Tables and show the maximum concentration resulting from each of the two source groups separately, i.e. the maximum concentration in the model domain with the other source effectively switched off. Tables and also show the maximum predicted concentration caused when both sources are operating at the same time. The individual source results are at the required percentile for short term SO 2 and as a result can not simply be added together to generate the combined source results. Furthermore, due to the variation in the dispersion profiles of the two sources, the maximum pollutant concentrations caused by each separate source do not occur at the same locations or the same hour of meteorological data. Consequently, the addition of the maximum concentrations caused by the two separate sources is not equivalent to the maximum predicted concentration of the two sources combined. Table shows that at a CHP chimney height of 35 m and a biogas engine stack height of 22 m, the CHP is producing a maximum PC of approximately 35 μg/m 3 to the east of the Site and the engines are producing a maximum PC of approximately 254 μg/m 3 to the west of the Site. This demonstrates that the combined impacts are therefore dominated by the biogas engine contribution and the maximum off-site PEC impacts are 261 μg/m 3 to the west of the Site. Raising the biogas engine stack leads to a reduction in the engine contribution (the CHP minimal contribution staying the same). Up to a stack height of 26 m the biogas engines maximum PC remains to the west of the Site and reduces to a contribution of 210 μg/m 3. At a stack height of

29 December m the biogas engine stack becomes sufficiently high above the surrounding buildings that the plume is no longer brought to ground on the boundary to the west of the Site, but now disperses to the east (like the CHP plume). This change in behaviour leads to significantly better dispersion and a reduction in the biogas engine PC to 57 μg/m 3. The combined PEC impacts at a CHP chimney height of 35 m and a biogas engine stack of 27 m is therefore reduced to 64 μg/m 3. Table shows that the CHP produces only a small percentage of the total amount of SO 2 therefore increasing the height of the CHP chimney has a negligible affect on the predicted maximum SO 2 PEC; this demonstrates that the PEC is dominated by the contribution from the biogas engines.

30 December Table 19-13: The effect of changing the biogas engine stack height on resultant predicted 15 minute averaged SO 2 concentration Description CHP Biogas Engine Max PC (µg/m 3 ) Max PEC (µg/m 3 ) Location of Maximum concentration Height Emission rate Height Emission rate (m) (g/s) (m) (g/s) X Y CHP Engines Combined CHP Engines Combined CHP Engines Combined CHP Engines Combined

31 December Table 19-14: The effect of changing the CHP chimney height on resultant predicted 15 minute averaged SO 2 concentration Description Location of Maximum concentration CHP Biogas Engine Max PC Max PEC Height Emission rate Height Emission rate (µg/m 3 ) (µg/m 3 ) X Y (m) (g/s) (m) (g/s) CHP Engines Combined CHP Engines Combined CHP Engines Combined

32 December Short Term (1 hour averaged) NO 2 Assessment The AQIA indicated that a 22 m biogas engine stack and a 35 m CHP chimney would result in a Predicted Environmental Concentration (PEC) for NO 2 of approximately μg/m 3 which is below the relevant EAL of 200 μg/m 3. This original assessment used the Waste Incineration Directive (WID) limits for NOx (200 mg/nm 3 ) but assumed that only 50% of NO x was NO 2 for the short term assessment. An additional, even more conservative estimate, with all NOx assumed to be NO 2 is considered below for the stack height sensitivity. The results of this assessment are illustrated in Table Table 19-15: The effects of changing the emission limit of NO 2 on the maximum PEC CHP Engines Max PC (µg/m 3 ) Max PEC (µg/m 3 ) Height (m) Concentration (µg/m 3 ) Emission rate (g/s) Height (m) Concentration (µg/m 3 ) Emission rate (g/s) From Table 19-15, we can see that increasing the NO 2 emission concentration while keeping the existing proposed stack height parameters increases the PEC from μg/m 3 to μg/m 3. The results are below the EAL of 200 μg/m 3. A biogas engine stack height analysis for NO 2 has also been performed so that the results for the stack options presented above for SO 2 can be considered. The results of this analysis are presented in Table Table demonstrates that changing the biogas engine stack height to 27 m has a great impact on the resultant NO 2 PEC due to the engine plume being dispersed across the Site in the same direction as the CHP plume. At a CHP chimney height of 35 m and a biogas engine stack height of 27 m, the combined off-site PEC impacts are predicted to be approximately 122 μg/m 3. Table demonstrates that increasing the height of the CHP chimney above 35 m has a negligible affect on the predicted maximum NO 2 PEC; the PEC of approximately 154 μg/m 3 is dominated by the contribution from the biogas engines.

33 December Table 19-16: The effect of changing the biogas engine stack height on resultant predicted 1 hour averaged NO 2 concentration Description CHP Biogas Engine Max PC (µg/m 3 ) Max PEC (µg/m 3 ) Location of Maximum concentration Height Emission rate Height Emission rate (m) (g/s) (m) (g/s) X Y CHP Engines Combined CHP Engines Combined CHP Engines Combined CHP Engines Combined

34 December Table 19-17: The effect of changing the CHP chimney height on resultant predicted 1 hour averaged NO 2 concentration Description CHP Biogas Engine Max PC (µg/m 3 ) Max PEC (µg/m 3 ) Location of Maximum concentration Height Emission rate Height Emission rate (m) (g/s) (m) (g/s) X Y CHP Engines Combined CHP Engines Combined CHP Engines Combined

35 December Additional AQIA Assessment Conclusions An additional assessment has been conducted into the impacts of changing the two different stack height parameters for the CHP and the biogas engines on the predicted short term impacts of SO 2 and NO 2. The results of the additional analyses show that increasing the biogas engine stack height has a much greater impact on reducing the maximum PEC than increasing the height of the CHP chimney above 35 m. This demonstrates that the biogas engines contribute a greater proportion of the total emissions from the ercf. At an engine stack height of 27 m, the biogas engine emissions are sufficiently above the adjacent ercf buildings and are no longer influenced by the building downwash on the western boundary. Instead the emissions from the biogas engines are dispersed to the east of the Site in the same direction as the emissions plume from the 35 m CHP chimney. As a result of the additional AQIA analyses, it can be stated with confidence that the CHP chimney does not need to be greater than 35 m above existing ground level. Furthermore, it should be noted that these analyses are considered to represent the most reasonable worst case, and make no consideration whatsoever of the introduction of filtration or abatement technologies within the stacks, nor do they consider the possibility of ducting the biogas engine exhausts through the CHP for use as combustion air Disposal of Ash Non-hazardous ash and residues from the ercf, (i.e. secondary aggregates from the MBT, bottom ash from the CHP and China Clay from the Pulp Facility), are secondary aggregates of use to the construction industry. Blackwater Aggregates has formally expressed an interest in pursuing opportunities associated with marketing such materials, and a letter of interest is presented in Appendix Residues resulting from the CHP gas scrubbing system or Fly Ash which are classified as hazardous waste will be transported from the Site in containerised vehicles for disposal within a suitably licensed off-site facility. With reference to the Environment Agency s web site there are presently 15 hazardous waste landfills operating across England and Wales. Considering the location and type of hazardous waste each site can accept, Table provides a list of the licensed facilities which could be used for the disposal of hazardous fly ash materials arising from the ercf s operation.

36 December Table 19-18: Licensed hazardous waste facilities Name Operator Address Waste types Range of Bostock Landfill Minosus Ltd Winsford, Cheshire inorganic, nonflammable waste. Stamford Road Slipe Clay Pit King's Cliffe Augean Ltd # Wide range of Landfill Cambridgeshire wastes. PE8 6XX Stoke Orchard Road Bishops Cleeve Grundon Waste Wingmoor Farm Cheltenham Management Ltd Gloucestershire GL52 4DG Port Clarence Landfill Port Clarence Huntsman Drive Augean North Ltd Landfill Stockton On Tees TS2 1NE Teesport, Grangetown, Teesport No. 3 Impetus Waste Middlesbrough, TS6 Landfill Management 6UG Coleby Road West Halton Winterton South Integrated Waste Winterton Landfill Management # North Lincolnshire DN15 9AP # Sites which are located closest to the ercf are highlighted. Wide range of wastes. Wide range of wastes. Wide range of wastes. Capacity (000t/yr) Traffic and Highways The following information is intended to address and clarify the comments raised by the Highways Agency within their consultation response of 13 November 2008 to ECC and the subsequent Regulation 19 Request for additional information presented within Appendix It is noted that subject to confirmation in relation to the following that the Highways Agency have indicated that they: could accept that this proposed development will not have a more adverse affect on the Trunk Road than the RCF already consented. 1. The number of staff referred to within the Transport Assessment should include the staff required to maintain the visitor centre; 2. The potential number of visitors per day to the Site; 3. Other modes of transport used by staff to travel to work. The Highways Agency suggests that Intermodal Transportation Limited recalculate the car/hgv movements to allow for all employees travelling by car either as drivers or passengers; and 4. Provide additional information to show the HGV distribution percentage to and from the Site on the A120.

37 December Additional Transport Assessment Calculations and Clarifications It is considered that any amendments to the assumed number of employee and visitor trips would be more than outweighed by rebasing the assessment year from 2022 to 2018, as requested by the Highways Agency. This is demonstrated in Table Table 19-19: Total Base Inflows at Site Access/A120 Junction Scenario Reduction Weekday AM Peak Hour Weekday PM Peak Hour Growth factors presented in Table have been calculated utilising the Version 5.4 TEMPRO datasets and applied to the observed flows shown on Drawings IT569/TA/02 and IT569/TA/05 (Chapter 10 of the Environmental Statement) in order to derive the 2018 base flows shown. The additional TEMPRO / NRTF calculations are presented in Appendix It should be noted that the 2022 base flows have been extracted from drawings IT569/TA/04 and IT569/07 (Chapter 10 of the Environmental Statement). The additional assessment has considered that that all employees would drive to the Site. It is anticipated that this would result in an additional 26 and 13 vehicular trips in the AM and PM peak hours respectively. The visitor centre would be operated on-demand by a member of the ercf management team, as and when visitors arrive. It should be noted that all visitors to the Site would ordinarily be required to arrange access; therefore, it is unlikely that visitor numbers will vary above 6 vehicles per day (inclusive of coach parties). The average visitor vehicular movements considered within the original Transport Assessment allowed for school children to arrive at the site by coach, and it is considered that at anyone time only one coach load of school children would be present on-site at any one time; due to the overall size of the proposed Education and Visitors Centre and for Health & Safety reasons. Therefore, even if an extremely robust position were adopted this would only lead to 1 additional vehicular movement being added to the weekday peak hour visitor centre traffic levels. The above demonstrates that re-basing the assessment year as requested by the Highways Agency would significantly outweigh any increases in traffic flows associated with the queries raised in relation to the staff and visitor traffic levels. Furthermore, it should be recognised that Table presented within Chapter 10 of the original Environmental Statement demonstrates that the 2022 with development inflows at the Site Access/A120 junction associated with the ercf s operation are significantly lower (some 88 and 166 vehicles respectively during the typical weekday AM and PM peak hours, than the corresponding 2025 flows associated with the original RCF application). Considering the comments raised within the Highways Agency, rebasing the assessment year to 2018 would result in the total with development inflows at the Site Access/A120 junction associated with the ercf operations being 233 and 329 vehicles lower during the typical weekday

38 December AM and PM peak hours than the corresponding 2025 flows associated with the RCF (for which ECC resolved to grant planning permission on the 30 March 2006). The Transport Assessments completed for both the original RCF proposal demonstrated that the existing Site Access/A120 junction will operate acceptably. It is therefore considered that no further assessment of this matter is required in conjunction with the current ercf proposal Predicted ercf Traffic Flows The predicted ercf traffic flows along the A120 have been calculated by considering the location of all know and proposed waste management and recycling facilities across the whole of Essex, used by the various District Councils, and the Routing Agreement which has been developed during negotiations with ECC for the RCF s Section 106 legal agreement, presented in Appendix Considering the strategic location of the various waste management facilities and the proposed Routing Agreement the predicted bias of the traffic flow along the A120 has been calculated and modelled as being: Eastbound Import and Export along the A120 (i.e. from Braintree) - 57½%; and Westbound Import and Export along the A120 (i.e. from Colchester) - 42½%. The calculations are presented in Appendix 19-5, and are considered to reflect the overall strategic location of the Site and the access it offers to the M11 and A12 corridors for both the import and export of materials. Both roads offer links to existing recycling facilities and the wider paper industry. It should be noted that materials will be imported and exported at a constant rate throughout the day to optimise the overall operational efficiency of the ercf. Therefore, concentrations or spikes in traffic movements will be generally avoided in line with operational best practice. The use of an integrated network of Waste Transfer Stations, the proposed Routing Agreement and the efficient operation of the ercf will optimise the use of the existing transportation network Surface Water The Environment Agency s (EA) letter of the 22 October 2008, referenced Development of an Integrated Waste Management Facility Rivenhall Airfield, Coggeshall Road, Braintree, CO5 9DF (Ref: AE/2008/106727/01-L01), presents a holding objection to the proposed ercf. The following additional information is intended to address the concerns raised associated with surface water proposals for the ercf. In the preparing this information Golder has agreed the approach required with technical representatives of the EA.

39 December Background Upper Lagoon will be a large freshwater storage lagoon, with an area of approximately 16,000 m 2, located in front of the ercf. The lagoon will provide storage for water which will be used within the ercf. It will be constructed below ground level to collect and store water from the following sources: Rainfall and surface water collected from the roofs of the ercf and areas of hardstanding around the Site; Groundwater pumped from the beneath the Site either during the construction phase of the works, or during the operation and management of the ercf; Water from the ercf processes, which has been cleaned and treated i.e. liquids arising from the MBT s bio-drying operation; Water transferred from Bradwell Quarry into Upper Lagoon; and Water which will be pumped from licensed surface water abstraction points held by GFC from the River Blackwater, or possibly from the local utility water supply network. Upper Lagoon will feature a freeboard to provide the necessary volume required for the storage and attenuation of storm water runoff from the Site. The freeboard in Upper lagoon will be maintained by a controlled discharge under gravity to New Field Lagoon. As noted in Chapter 6 of the Environmental Statement, pre-application consultation with Keith Grimwood of the EA has revealed that the transfer of water between Upper Lagoon and New Field Lagoon will not be subject to a Transfer Licence. New Field is the lowest point of the restoration scheme within Bradwell Quarry (Site R in the Essex Minerals Local Plan). The proposed restoration of New Field includes a large surface water collection lagoon (New Field Lagoon) area IOH 124 Greenfield Runoff To address the first point raised by the EA s holding objection, the Institute of Hydrology Report 124 (IOH124) has been used to obtain the greenfield runoff rate from the Site. The following input values have been applied: AREA 21.5 ha; SAAR 585 mm (from FEH); and SOIL Type 3 (from FSR WRAP Map) ha of existing hardstanding on the Site has been accounted for in the greenfield runoff by applying the urban estimation, given in IOH124. The Thames area growth factor for a 1 in 100 year return period (3.19) has also been applied, to give a 1 in 100 year greenfield runoff rate of l/s/ha. The calculation is presented in Appendix 19-6.

40 December Rational Method Post ercf Development As agreed with the EA, the post development surface water runoff assessment has been carried out using the Rational Method to consider the surface water runoff generated on the Site during a storm event. The Rational Method has been used to calculate the required storage volumes during different duration rainfall events with different rainfall intensities. The 1 in 100 year return period rainfall event (1% probability of occurring every year) plus an increase of 30% to account for climate change up to 2115 has been applied. A simplification of the Rational Method has been used to calculate the required storage volumes during different duration rainfall events with different rainfall intensities using the following equation: V = C P A Where: V = Surface Water runoff volume (m 3 ); P = Total storm rainfall for storm events with a 1% probability of occurrence every year (m) C = Runoff coefficient (ground surface specific, dimensionless); and A = Area of the Site (m 2 ). The assessment uses total rainfall depths, taken from the Flood Estimation Handbook CD-ROM (FEH, 2006), for storm durations between 15 minutes and 24 hours. The surface water runoff volumes have been calculated assuming that the entire Site (21.5 ha or 215,000 m 2 ) will be covered by hardstanding. The runoff coefficient, to account for infiltration, evaporation and depression storage, has been taken as 0.95, a conservative value for the hardstanding that will cover the proposed development. The calculation of storage volume considers the 1 in 100 year greenfield discharge rate of l/s/ha. The critical storm duration for this runoff rate was found to be three hours. The storage required for this storm duration was found to be approximately 14,450 m 3. Storm water runoff calculations are presented in Appendix Storm Water Attenuation A discharge will be set in Upper Lagoon at 40 maod to provide a freeboard of 1 m below the maximum water level of 41 maod, this is shown in Figure 3.14A. This freeboard will provide the volume of storage required to attenuate the 1 in 100 year +30% storm runoff volume. The

41 December discharge will be limited to l/s/ha and flow to New Field Lagoon. The control mechanism along the controlled discharge pipe will comprise a hydrobrake Summary of Additional Surface Water Information To address the concerns raised by the EA associated with surface water proposals for the ercf, the Institute of Hydrology Report 124 (IOH124) has been used to obtain the 1 in 100 year greenfield runoff rate from the Site and a post development surface water runoff assessment has been carried out using the Rational Method. The following confirms the findings of the additional assessment: The 1 in 100 year greenfield discharge rate from the existing site is estimated to be l/s/ha; Upper Lagoon will feature a freeboard of 1 m to provide storage for the estimated 1 in 100 year return period event +30% volume of approximately 14,450 m 3 ; and Discharge from Upper Lagoon to New Field Lagoon will be controlled to the Q100 greenfield discharge rate. In addition to the surface water assessment presented within Chapter 6 of the Environmental Statement, the provision of the above additional information identifies the likely impacts on surface water hydrology and surface water quality resulting from the proposed ercf at Rivenhall Airfield Ecology The following information is intended to address and clarify the comments raised by the Buglife within their consultation response of 30 October 2008 to ECC and the subsequent Regulation 19 Request for additional information presented within Appendix Additional Ecological Information The Ecological Assessments presented within Chapter 6 of the Environmental Statement makes no reference to invertebrates, either to consider the impacts of the proposed ercf on invertebrates, or to justify their omission from more detailed consideration. However, it is confirmed that the latter is applicable. It should be noted that at the Scoping Stage invertebrates were indeed considered as a part of the overall ecological assessment, although it was determined that no detailed investigation of invertebrates was relevant for the ercf. The justification of this is as follows: 1. There is no habitat present that will be affected which is likely to support important invertebrate communities. Here we take each habitat in turn and explain its significance for invertebrates:

42 December Woodland and Scrub: The Site 1 contains few mature trees and a rather sparse ground flora. There are no trees of antiquity, with the oldest trees across the whole Site being no more than 80 years old. The main blocks of woodland are relatively young, being approximately 40 years old and have not developed the structural complexity and species diversity that would be of significance to the more notable invertebrate communities (e.g. dead wood, peeling bark, sap runs). Scrub habitat is generally compact and contained in discrete areas rather than being scattered across the Site in a more chaotic mosaic. Accordingly, the value of this scrub habitat is lessened for invertebrates. It is of note that the main area of scrub within the Site surrounds Woodhouse Farm. This scrub would not be removed, although favourable management would take place to increase its biodiversity value, including its value for invertebrates; - Open Habitats: The Site is part of an intensively managed landholding, with arable agriculture being the main land-use. Accordingly, the majority of open habitats across the Site are intensively managed arable fields that are of low value for invertebrates, typically supporting only a generalist species assemblage. Other fields of semi-improved grassland are generally species poor, floristically poor and structurally homogenous. Again, these habitats are of low value for invertebrates. In addition to this, the farmer uses pesticides on the arable fields, such as herbicides, fungicides and insecticides. This effectively sterilizes the arable fields and the impact of spray drift can be damaging on non-target organisms, especially those in the immediate surrounds. The only field that is of greater potential value for invertebrates is that to the northeast of Woodhouse Farm. This would be lost to the development. Whilst it has a greater number of plant species, such that it may be regarded as semi-improved neutral grassland, floristically it still has a low proportion of forbs, such as St. John s-wort Hypericum sp. and common knapweed Centaurea nigra and is predominantly comprised of grass species. In discrete patches there are small areas of short perennial vegetation and tall ruderal vegetation. Short perennial vegetation is primarily located on the concrete lining of the former runways, with red fescue Festuca rubra and English stonecrop Sedum anglicum being most abundant. Tall ruderal vegetation chiefly occupies a band to the northwest of the proposed Facility, in the proximity of a screening bund made of topsoil. This is also species poor with various thistles Cirsium sp., fat hen Chenopodium album and bristly oxtongue Picris echioides being abundant. Such examples of short perennial and tall ruderal vegetation are not considered to be of significance to notable invertebrate communities, primarily due to their isolated nature to the northwest of the Site (e.g. they are distant from other semi-natural vegetation such as the scrub, woodland and grassland habitats), a lack of structural diversity (e.g. not combined with other vegetation, as part of a habitat mosaic), and a lack of species diversity. It should also be noted that bare earth is also present at the Site. Bare ground would normally be earmarked as important invertebrate habitat. However, the only areas of bare ground at the Site exist along the existing access road, which is inhospitable to invertebrates due to permanent disturbance; and also in unvegetated parts of the runways, although these are inappropriate for most invertebrates of bare ground due to there being no burrowing substrate in the concrete; - Ponds: Generally, the ponds across the Site are low quality examples of pond Biodiversity Action Plan (BAP) Priority habitat. This is due to the level of shading across the majority of ponds and high accumulations of silt. The only ponds that will be directly affected by the scheme are those surrounding Woodhouse Farm. These ponds would be favourably managed resulting in a net biodiversity gain. 1 All reference to the Site is in relation to the area covered by the Planning Application red line boundary.

43 December It is accepted that cumulatively the Site comprises a range of habitats such as grassland, scrub, bare ground, perennial and ruderal vegetation. Indeed this would suggest that the UK BAP Priority Habitat - Open Habitat Mosaics on Previously Developed Land is applicable. However, the distribution and abundance of each of these individual vegetation types is such that only small patches exist and where these exist they are discrete and separate from other patches. Accordingly, the Site is judged to be of lower value when considering the BAP Priority Habitat. For example, Priority Habitat would typically comprise: mosaics of bare ground with, typically, very early pioneer communities on skeletal substrates, more established open grasslands, usually dominated by fine-leaved grasses with many herbs, areas of bare ground, scrub and patches of other habitats such as heathland, swamp, ephemeral pools and inundation grasslands (UK Biodiversity Partnership, Species and Habitats Review, Open mosaic habitats on previously developed land, Summary Statement p107, Habitat Proposal p144). Furthermore, high quality examples may be characterised as "unmanaged flower-rich grasslands with sparselyvegetated areas developed over many years on [edaphically-] poor substrates" (Harvey 2000, referring to the East Thames Corridor, but it applies to all types). Such a range of habitats might exist elsewhere in other areas adjacent to the Site (e.g. Bradwell Quarry). However, given that much of the Site is either intensively managed farmland or recently established woodland, this reduces the significance of the Site in terms of the BAP Priority Habitat - Open Habitat Mosaics on Previously Developed Land; 3. The impact of airborne pollution is not considered to be significant on invertebrates. This is substantiated by the Ecological Risk Assessment presented within the Environmental Statement which identifies negligible impacts upon terrestrial wildlife (identified receptors included pheasant and brown hare) considering both baseline and future conditions. Accordingly, future chemical releases are not expected to result in harm to ecological receptors either at the Site or in its surrounds; 4. It is reasonable to assume that there are no species included on the Essex BAP that could sustain a viable population at the Site. Similarly those species listed on the UK BAP are also unlikely to be reliant on the Site or be capable of sustaining viable populations. This is due to the absence of habitats of high ecological integrity, either in their own right or as habitat mosaics; and the isolated location of the Site within an intensively managed agricultural landscape; 5. A carefully thought out mitigation scheme provides opportunities for invertebrates, in particular providing greater continuity of existing and proposed habitats across the Site. This would be implemented through an Ecology Monitoring and Management Plan that would be prepared in consultation with Natural England, Essex Wildlife Trust and Braintree District Council. Measures included in the mitigation proposals are as follows: - Of the existing woodland and scrub, approximately half would be lost to the development (1.6 ha woodland and 0.6 ha of scrub), although this would be offset by an equivalent replacement with newly planted woodland, scrub and hedgerow. This new habitat would, however be of considerable benefit as it would provide continuity between habitats around the Site, including links to more mature woodland, such as Maxey s Spring to the northwest of the proposed ercf; - In terms of open habitats there is no requirement to replace loss of arable land due to its low ecological value. However, 1.2 ha of new grassland would be created and an existing 1 ha area of poor semi-improved grassland to the southwest of Woodhouse Farm will be managed to increase its biodiversity value;

44 December Whilst no ponds will be adversely affected by the proposed scheme, favourable management of the moat around Woodhouse Farm will be implemented, through the Ecology Monitoring and Management Plan; and - Concrete removed from the aircraft runway will be retained and reused for the benefit of flora and fauna. Thus, crushed concrete will be spread over the roof of the ercf. This is a lime rich substrate that over time will support a calcicolous community of plants, typical of impoverished soils. This would be a marked improvement on the existing situation whereby the concrete at the Site is consolidated into single strips along the runways and its impermeability means that it is less readily colonised initially by plants and secondarily by the fauna that feed off such plants and within the shallow soil of decomposing plant material that starts to develop. 6. Quarries can be very important sites for invertebrates and it could be assumed that Bradwell Quarry has a range of habitats, including bare ground, scrub, south facing cliffs and steep banks, and patches of ephemeral and ruderal vegetation, all of which would are likely to be of greater significance to invertebrates, owing largely to the substrate type of the quarry, which includes clay, sands and gravels. However, the quarry will not be impacted by the ercf and its access road will be constructed across the restored pit, this obviates the requirement for further survey. In light of Buglife s concerns regarding the proposed development, it should be noted that opportunities for invertebrate habitat improvement have been maximised (within the constraints of the development) and also that opportunities for learning about the restoration are promoted. Accordingly, it is proposed that following the construction of the ercf a review of the existing mitigation measures is undertaken to identify where habitat creation can be achieved through a directed form of natural regeneration. In parallel with this, these habitats would be monitored as part of the Ecology Monitoring and Management Plan, with a key objective being to monitor the rate of colonisation of invertebrates across the Site. GFC would be pleased to report the findings on a periodical basis to Buglife as well as statutory consultees including Natural England and Braintree District Council Trees An additional tree survey has been completed to reflect the comments of the ECC Tree Officer made on the 22 October The impact of the ercf on the trees within the red line boundary has been included, however it should be noted that these trees would be removed as part of the existing RCF scheme for which ECC resolved to grant planning permission on the 30 March A Tree Constraints Plan (TCP) has been prepared showing extents of Root Protection Areas and shadow patterns of retained trees. The TCP incorporates a Tree Protection Plan showing the location of trees to be removed or retained and the location of protective fencing, shown in Figure This drawing also shows the protection required to areas of proposed soft landscape treatment.

45 December The arboricultural implications assessment consists of a short report looking at the implications of the development for each of the retained trees and in particular the impact of lowering the ercf into the ground by at least 15 m on adjacent woodland. For clarification, it is not proposed to translocate any trees on Site, but where mature specimens are removed, their trunks will be utilised on site as standing monoliths to create deadwood habitats. However, it should be noted that the retention of the existing woodland is important to the ercf, therefore it will fall under the Ecology Monitoring and Management Plan. It is proposed that the existing woodland will be managed and maintained by implementing arboricultural management to promote growth and reinforce the existing woodland. The location of proposed new tree planting areas are shown on Figures 19-3 and Additional Tree Survey An additional survey was undertaken in accordance with the recommendations of BS5837: 2005 Trees in Relation to Construction on the 26 November It is based on a topographical survey completed by East Anglian Land Surveys Ltd to confirm the height and location of the trees within and adjacent to the Site of the ercf The Site The Site comprises areas of rough grassland and arable crops between remnants of former concrete runways and hangar, associated with the Site s prior use as an airfield. Tree Preservation Order (TPO) No 11/2001 has been issued by Braintree (confirmed in June 2001) covering the area around Woodhouse Farm, Kelvedon. The extent of the TPO was used as the basis for the tree survey and is presented on Figure It should be noted that a Schedule describing the specific trees, groups of trees or woodland at each location covered by the TPO was included in Appendix 8.2 of the Environmental Statement. The reference numbers used in the TPO have also been applied to this tree survey. The additional tree survey work has focused on those trees within, or directly adjacent to, the ercf s red line boundary; therefore trees located some distance from the Site, i.e. the Wayfarers Site, have not been included. The trees were not tagged as it was considered that they could be identified from the topographical survey The Trees Following discussions with ECC s Tree Officer, the additional tree survey has focussed on three main areas of woodland, namely: Areas W2 and W3 within the ercf s red line boundary; and Area W1 which lies between Woodhouse Farm and the ercf Four smaller areas of woodland, G1, G2, G3 and G4 also fall within the red line boundary, together with six mature oak trees (T1, T4, T5, T6, T7 and T8) which are all located around the existing hangar. A row of poplars (G15) lies to the west of Woodhouse Farm and three pear trees

46 December (T11, T12 and T12a) and a walnut tree (T10) lie within the garden of the Farm. The tree schedule is presented as Table Implications of the Proposed Development The proposed ercf would require removal of the following trees or groups of trees: T1, T8, G1, G2, G4, part of W2 and part of W3. These are all Category A trees as categorised in accordance with BS5837. Root Protection Areas (RPA) for individual trees T3, T4, T5, T6 and T7 are shown on the Tree Constraints and Protection Plan (Figure 19-2) as circles encompassing the maximum spread of these trees. This RPA has formed a guide for determining the location of the protective barrier fencing shown on Figure 19-3 that forms the Construction Exclusion Zone (CEZ). In removing parts of woodland areas W2 and W3, the retained trees will form a new edge. This new edge would be defined by a retaining wall with tree protection fencing sufficiently set back to allow room for construction (Additional reference should be made to Chapter 3 of the Environmental Statement). The canopies of trees would not overhang this fence, therefore some trees would be removed within the retained parts of W2 and W3. The ercf will be lowered by at least 15 m into the ground, therefore there is a risk that existing retained trees directly adjacent to the ercf could become dewatered. However, it should be noted that the retention of the existing woodland is important to the ercf, therefore it is intended to coppice those trees lying within 5 metres of the retaining wall that would respond to such treatment. In addition, it should be noted that the woodland would fall under the Site s Ecology Monitoring and Management Plan. It is proposed that the existing woodland will be managed and maintained by implementing arboricultural management to promote growth and reinforce the existing woodland. The condition of the retained trees in W2 and W3 will be monitored as will the ground water conditions, and if it is found that dewatering is causing dieback, remedial action will be taken, such as watering from Upper Lagoon Tree Protection The trees to be retained would be protected by the use of stout fencing erected along the lines indicated on the Tree Constraints and Protection Plan (Figure 19-3). The specification of the fencing would be as that recommended in Section 9 of BS5837: 2005, The construction of exclusion zones: barriers and ground protection. The Construction Exclusion Zone (CEZ) creates a sacrosanct no-go area for construction workers, therefore the barrier fencing would be erected before any site excavation work commences. Within the CEZ there is to be no unauthorised excavation or change in soil level, so that trees can be successfully retained and survive the development with good vitality.

47 December Table 19-20: Additional Tree Survey Prefix T = Tree, S = Shrub, G = Group, H = Hedge, W = Woodland. Stem Ø Trunk diameter in millimetres measured at 1.5 metres above ground level (not included for multi-stemmed trees). Spread Maximum crown radii in metres measured on the four cardinal points. Hgt Height (estimated) in metres taken from topographical survey. Crown Height in metres of crown clearance above adjacent ground level Age Age class (Y young, MA middle aged, Mat mature, OM over mature, V veteran) Phys cond Physiological condition Good, Fair, Poor, Dead Condition and Recommendations Structural condition and record of defects together with any preliminary management recommendations as underlined. RPA (rad) Recommended protection area. Dimension in metres = radius of circle from the centre of stem. Erc Estimated remaining contribution in years (less than 10, 10-20, 20-40, more than 40) BS grade R Trees that should be removed, A1-A3: Category A High quality; Trees that are highly desirable for retention, B1-B3: Category B Moderate quality; Trees that are desirable for retention, C1-C3: Category C Low quality; Trees of no particular merit, could be retained. Asy Asymmetric canopy to compass direction N S E W Compass point direction, may also appear as NE e. Estimated dimension agl Above Ground level m/s Multi-stemmed Remove deadwood Remove deadwood, significantly diseased or decayed growth, crossing or torn branches. Branch stubs and tears to be cut clean. All work to be carried out in accordance with BS3998 and current best practice. Bat From bat roost potential inspections of trees. Ph1 Ecology Phase 1 habitat survey. All the following trees are included within the Tree Preservation Order but not all are within the red line boundary of the development.

48 December No Species Latin Hgt Stem Ø mm at Branch Spread (in m) 1.5 m N E S W Height of crown clearance Age Phys Cond Structural condition and preliminary management recommendations Erc BS grade RPA (rad then m 2 ) T1 Oak Quercus robur Mat G (T7 Bat) Located on steeply sloping ground on edge of a ditch, base leaning into ditch. Two main trunks, forked low down (0.5m) forming weak point at join. Ivy-covered up trunk and into branches. Ground ploughed beneath 75% of canopy. Forms end of hedge line consisting of two large hazel stools. To be removed as part of development. T2 Oak Quercus robur Mat G Within G1 (T8 Bat). Not a Crab Apple as described on the TPO. One of other similar sized oaks within this block of woodland. Branched mainly to the northwest with other sides constrained by adjacent trees. 40+ A2 NA 40+ A2 NA To be removed as part of development. T3 Oak Quercus robur Mat G Within G2 (T9 Bat). One of other similar sized trees within this linear strip of woodland. Ivy covered trunk and into branches. 40+ A To be retained as part of G2 to continue to provide valuable screening.

49 December No Species Latin Hgt Stem Ø mm at Branch Spread (in m) 1.5 m N E S W Height of crown clearance Age Phys Cond Structural condition and preliminary management recommendations Erc BS grade RPA (rad then m 2 ) T4 Oak Quercus robur to 0.9 Mat G (T5 Bat) Growing intertwined with T5. Low branched, with main branches at 90 to trunk. Wide spreading with no clearance under lowest branches. Growth mainly to the eastern side reflecting prevailing wind conditions. Could be a commemorative tree, planted by airman stationed at the base. 40+ A2 and A Inc d to 9 rad to allow for growth on east. Should be retained as a pair or would become one-sided if one was removed. T5 Oak Quercus robur to 1.15 Mat G (T6 Bat) As for T4 above. 40+ A2 and A T6 Oak Quercus robur to 0.9 Mat G (T5b Bat) Growing intertwined with T7. As for T4, low branched and wide spreading with no clearance under branches. Should be retained as a pair or would become one-sided if one was removed. 40+ A2 and A3 T7 Oak Quercus robur to 1.25 Mat G (T5a Bat) As for T6 above. 40+ A2 and A Inc d to 9.7 rad to allow for growth on northeast Inc d to 10.4 rad to allow for growth on east.

50 December No Species Latin Hgt Stem Ø mm at Branch Spread (in m) 1.5 m N E S W Height of crown clearance Age Phys Cond Structural condition and preliminary management recommendations Erc BS grade RPA (rad then m 2 ) T8 Oak Quercus robur to 1.15 Mat G (T5d Bat) Good form as a single specimen in open ground unhindered by other trees. Low branched and wide spreading with no clearance under branches. 40+ A2 and A3 NA T9 Ash Fraxinus excelsior To be removed as part of development Mat G One of several mature trees in a woodland strip bounding the public right of way to Woodhouse Farm. Ivy covered up trunk. 40+ A2 NA Outside red line boundary therefore unaffected by development. T10 Walnut Juglans regia OM F (T4 Bat) One cavity and some loose bark (high bat potential). One main limb dead and other smaller dead branches with signs of storm damage. Small for its obvious age B2 NA On site boundary and unaffected by development. T11 Pear Pyrus communis OM F (T3 Bat) Some loose bark and deadwood present (moderate bat potential). Good fruiter. Thin branched almost to ground level B T12 Pear Pyrus communis To be retained in garden to Woodhouse Farm OM F (T1 Bat) Many crevices, at least one cavity and abundant dead wood on limbs (high bat potential). Hollow at B

51 December No Species Latin Hgt Stem Ø mm at Branch Spread (in m) 1.5 m N E S W Height of crown clearance Age Phys Cond Structural condition and preliminary management recommendations Erc BS grade RPA (rad then m 2 ) base, but good fruiter. T12a Pear Pyrus communis To be retained in garden to Woodhouse Farm OM P (T2 Bat) Some loose bark and deadwood present (moderate bat potential). Large scar to half of trunk with hollow base apparent. Elder growing from base B T13 Ash Fraxinus excelsior T14 Crab Apple Malus sylvestris G1 Mixed woodland mainly of oak, with occasional field maple and hawthorn. Quercus robur, Acer campestre, Crataegus monogyna,, etc. To be retained in garden to Woodhouse Farm Mat G Wide spreading tree in open ground. Six main stems from base. Outside red line boundary therefore unaffected by development Mat G Densely branched tree in open ground. Approx 15 Various Overhangs perimeter concrete path. Variable MA to Mat Outside red line boundary therefore unaffected by development. G (Includes T8 Bat) Listed on TPO as 13 Oak, 2 Hawthorn, 1 Crab Apple. Includes T2 and also contains blackthorn, hazel, elder, rose and bramble to northwest of dry ditch. To be removed as part of development. 40+ A2 NA B2 NA 40+ A2 NA

52 December No Species Latin Hgt Stem Ø mm at Branch Spread (in m) 1.5 m N E S W Height of crown clearance Age Phys Cond Structural condition and preliminary management recommendations Erc BS grade RPA (rad then m 2 ) G2 Mixed woodland mainly of oak, with field maple and hawthorn Quercus robur, Acer campestre, Crataegus monogyna, etc Approx 15 Various Up to 10m radius from bole of mature specimens. Variable MA to Mat G Linear belt of trees (including T3) to southeast of dry ditch. Listed on TPO as 14 Oak and 3 Hawthorn, but also contains mature ash and field maple. Some dead elm, some falling into ditch, with understorey of blackthorn and rose. 40+ A2 2m beyond extent of canopy G3 Mixed woodland mainly of oak with 2 pines. Quercus robur, and Pinus sylvestris, Approx 15 Various Up to 10m radius from bole of mature specimens. Variable MA to Mat To be retained within the development to provide valuable screening. G (Includes T5c Bat and Target Note 26 Ph1). Listed on TPO as 12 Oak, 2 Pine, 3 Maple, 1 Hawthorn and 1 Willow. Also 1 mature poplar and understorey of scrub. Oak at northwest end of bed similar in stature to T6 and T A2 2m beyond extent of canopy G14 Oak, Apple, Ash and Pine Quercus robur, Malus sylvestris, Fraxinus excelsior, Pinus sylvestris Approx 15 Various Up to 8m radius from bole of each tree. To be retained within the development. Variable Mat G (T5e, T5f and T5g Bat) Listed on TPO as 1 Oak, 1 Pine, 1 Crab Apple, and 1 Maple. Individual standard trees to east side of footpath edge. Outside red line boundary therefore unaffected by development. 40+ A2 NA

53 December No Species Latin Hgt Stem Ø mm at Branch Spread (in m) 1.5 m N E S W Height of crown clearance Age Phys Cond Structural condition and preliminary management recommendations Erc BS grade RPA (rad then m 2 ) G15 Mixed woodland strip but mainly Lombardy poplar Populus nigra Italica 15.2 to 18.5 (aver 16.9) Various Varies To GL Mat F Listed on TPO as 20 Lombardy Poplar, but only 8 main stems surveyed. Also some mature oak with other smaller trees such as hawthorn and blackthorn to either side of a former concrete track forming an impenetrable hedge. Poplars reduced in height in past to about 6-7m with potential for decay pockets at pruning points. Closer examination required to check for branch failure B2 2m beyond extent of canopy G16 G17 Linear tree belt mainly of Poplar with occasional Oak Linear tree belt mainly of Willow Populus sp Quercus robur Salix sp Quercus robur Acer campestre Malus sylvestris Approx 17 Approx 15 Retained as part of conversion of Woodhouse Farm. Various Varies To GL Mat G Listed on TPO as 9 Poplar and 1 Oak. Linear belt of trees with scrub to the base. Outside red line boundary therefore unaffected by development. Various Varies Variable Mat G Listed on TPO as 3 Oak, 30 Willow, 2 Maple and 1 Crab Apple. Some willows falling into dry moat. On edge of red line boundary therefore unaffected by development to 40+ B2 B2 NA NA

54 December No Species Latin Hgt Stem Ø mm at Branch Spread (in m) 1.5 m N E S W Height of crown clearance Age Phys Cond Structural condition and preliminary management recommendations Erc BS grade RPA (rad then m 2 ) W1 A woodland of mainly Oak, Pine and Hawthorn Quercus robur, Pinus sylvestris, Crataegus monogyna Approx 15 Various m/s Edge of canopy forms red line boundary. GL to 2 Y to Mat G (Target Note 27 and 30 Ph1) Semi mature woodland dominated by oak, with pine, elder and holly, abundant grey willow and blackthorn, occasional apple. Cherry plum listed on TPO not observed. No evidence of management. 40+ A2 2m beyond extent of canopy W2 A woodland of mainly Oak, Poplar, Hawthorn and Crab Apple Quercus robur, Populus sp, Crataegus monogyna, Malus sylvestris Approx 15 Various m/s Varies GL to 2 Y to Mat G Edge of woodland forms the red line boundary therefore offset fencing 2m from canopy edge to ensure protection from development. (Target Note 24 Ph1) Semi mature woodland with occasional mature trees mainly of oak, with elder, field maple, willows, hawthorn, crab apple, hazel and poplar (one distinct stand). 40+ A2 2m beyond extent of canopy W3 A woodland of mainly Oak, Hawthorn and Blackthorn Quercus robur, Crataegus monogyna, Prunus spinosa Approx 15 Various m/s Varies GL to 2 Y to Mat G Partly removed. (Target Note 25 Ph1) Semi-mature woodland with abundance of oaks. Dense blackthorn and obvious planted trees such as Scots pine. Partly removed. 40+ A2 2m beyond extent of canopy

55 December Visual impact Access to the Site will be provided via a private access road from the existing A120 and the extension of the road approved by ESS/38/6/BTE. The existing access into the Site from the A120 is provided by an at-grade junction which was constructed in The existing access road comprises the following: A river crossing over the River Blackwater (two open lattice bridges); A section of two-way road up to the point of crossing Church Road, followed by single track tarmac road with passing bays leading across Ash Lane and into the plant; and Crossings of Church Road and Ash Lane at grade with restricted single lane crossing for the access road and concreted bollard surrounds to prevent lorry movements into or from these country lanes. All mineral operations traffic is restricted to the use of the access road and junction onto the existing A120. The ercf will share the existing private access road to the A120; hence, these proposals are planned to be an integral part of the overall master planning and operation of the larger site. It should be noted that planning permission ESS/07/98/BTE Rivenhall Airfield Mineral Extraction Site R incorporating Bradwell Sand and Gravel Pit, included Screening of the New Access Road. There was a significant amount of new hedgerow, tree and copse planting in the area affected by the access road. Along the southern boundary of the A120 junction, planting of trees and hedgerows reinforced existing screening. Existing hedgerows were strengthened along the first length of the access road to the River Blackwater. From the River Blackwater up to the crossing with Church Road had new hedgerow planted along its full 400 m length, including a field corner spinney at Church Road. Between the Church Road and Ash Lane crossings, the access road has been lowered into a 1.5 m cutting with a 1.5 m spoil mound amounting to up 3m of screening. In addition, a new hedgerow was planted along the southern side of Church Road returning into Ash Lane with a widened landscape area shielding the access road from the setting of the Church. Drawing RK/PA/03 is presented in Appendix 19-7, and shows the landscaping measures that were implemented as part of planning permission ESS/07/98/BTE. Photographs illustrating the existing landscaping measures from the Church, Footpath 58 and Bradwell village are presented below. In addition, a photograph has been taken from Footpath 58 looking towards Bradwell Hall to indicate the density of existing the hedgerows and trees which screen the access road from view.

56 December Views of the existing site access road from the Church. Views of the existing access road from Footpath 58. Views of the existing hedgerows and woodland screening the site access road from Bradwell village, and a photograph indicating the density of existing the hedgerows and trees which screen Bradwell Hall.

57 December On the 30 March 2006, ECC resolved to grant planning permission for the RCF, ESS/38/06/BTE. A comparison of the proposed ercf and approved RCF transport movements are presented below:

58 December Therefore, in considering the visual impact of vehicle movements along the existing site access road, the impact of the ercf on the surrounding environment has been benchmarked against those established by the RCF and the existing quarrying operations. Furthermore when considering the visual impact of the existing access road on Bradwell Hall and Bradwell village, it should be noted that existing hedgerows and tree lines planted along the line of the access road and long established field boundaries screen the road from view. Proposals for the ercf access road have not been changed from those previously granted or resolved to grant permission by ECC. Neither is there an increase in HGV traffic on the access road Design The design of the Upper Lagoon has been given a great deal of consideration to make a feature of it at the entrance to the site, though there are a number of constraints on its design. Upper Lagoon will be constructed below surrounding ground level. The margins of the lagoon will be widened in order to create an area of planted wetland habitat. The depth of water in the lagoon will fluctuate on both a seasonal and operational basis; as water is abstracted for use within the ercf s treatment and recycling operations, compensatory pumping to replenish water levels in the moat at Woodhouse Farm and use in the arboricultural management of the existing woodlands. Therefore the shallow margins will create a varied wetland habitat of ecological value. The design of the northwest elevation of the ercf has been revised to create a symmetrical frontage by having two arches of the same dimensions, each spanning 109 m. The modification is presented on Figures 3-8A, 3-12A and 3-19A. This change would be imperceptible on Photomontages presented within existing Landscape and Visual Impact Assessment given the distance of the view from the various elevations and the location of intervening vegetation. As noted within the Construction and Operations Assessment, established in March 2000, the Essex Public Art Strategy encourages the provision of new works of visual art and craft as an integral part of all building projects and environmental improvement schemes, public or private, within the County. The Elephant House (the former airfield fire station) is located approximately 100 m to the south of the Site. This building was used as a fire station by the USAF during World War II. Inside the Elephant House are a number of wall murals drawn by the servicemen who served at Rivenhall Airfield. These murals are currently neither visible nor accessible to the general public. It is proposed that the frontage of the ercf be used as a canvas on which Public Art could be displayed to present a record of the Site s heritage and former use as an airfield. By doing so the frontage of the ercf will create a visual backdrop to Upper Lagoon. Therefore, subject to agreement with ECC and the USAF, it is proposed that wall murals from the Elephant House

59 December and images of the 397 Bombardment Group are reproduced and displayed on the front of the ercf as Public Art, visible to both operators and visitors to the Site. The following indicates the range and style of images that could be considered for use as Public Art, the existing Elephant House wall murals which provide an accurate reference as to the names and style of the 397 Bombardment Groups art work, and a photograph of the Missouri Mule when based at Rivenhall Airfield.

60 December General Layout Figure 19-5 presents a 1:1000 base plan of the proposed ercf and Woodhouse Farm showing the layout of the ercf, the retained existing planting; proposed planting, the circulation of vehicles into the ercf and up to Woodhouse Farm and the layout of the staff and visitors car park Listed Buildings Two buildings are listed as being of Special Architectural Interest. Woodhouse Farm is a Grade II Listed Building, which will be redeveloped (as part of a proposed Education Centre linked to the ercf operations) following a detailed application for and receipt of listed building consent from the Local Planning Authority according to Section 7 of the Planning (Listed Buildings and Conservation Areas) Act 1990 (c. 9). The adjacent outbuilding, known as The Bakehouse, is also a Grade II Listed Building in an extremely dilapidated condition. A simple iron rocking hand water pump, located on the southern side of this outbuilding, is also Grade II listed. It is accepted that legal agreements will for the refurbishment of the listed buildings in accordance with English Heritage guidance and PPG 15 will be drawn up by ECC. It should be noted that a condition of the resolution to grant planning permission for the RCF on the 30 March 2006 was: No redevelopment of the Woodhouse Farm complex shall take place until a scheme outlining the mechanisms and timetable for securing the appropriate Listed Building consents and detailed planning permission for conversions, access and car parking from Braintree District Council has been submitted to and approved in writing by the Waste Planning Authority. No beneficial use shall take place of the visitor and education centre until the works prescribed in the scheme have been implemented The Grade II Listed Pump It is confirmed that the Grade II listed pump has been located following an extensive search of Woodhouse Farm. The water pump is located on the southern side of The Bakehouse, at TL This early 19 th century structure is surrounded by dense overgrown vegetation which serves to protect its location.

61 December The pump is located over a deep brick lined well (its estimated that the diameter of the well shaft is of the order of 4 ft). On the 28 November 2008 the depth of the groundwater within the well was m below ground level. It was also confirmed that the well was greater than 30 m in depth, and is therefore installed within the deeper Chalk aquifer. This is verified by the various borehole logs which have been drilled across the Site. The groundwater dewatering associated with the proposed ercf is to be within the sands and gravels only. There will be no impact on the groundwater levels of the Chalk, and thereby the listed pump, since this is isolated from the sands and gravels by the underlying London Clay. There is unlikely to be a residual impact on the quality of water from which the pump draws as a result of spills or leaks of fuel or oil during the construction and operational phases of the Site, following the implementation of the mitigation proposals put forward within the existing Surface and Groundwater Assessment. The Grade II listed pump will be restored to working order as part of the overall refurbishment, improvement and redevelopment of Woodhouse Farm Woodhouse Farm Cross Section Figure 3-18A presents a revised cross section indicating the primary and secondary screening offered by the existing hedgelines and woodland Staff and Visitor Car Park Figure 19-4 presents a 1:1000 plan of the proposed ercf and Woodhouse Farm and potential architectural arrangement of Woodhouse Farm. It should be noted that the area allocated for the staff and visitor car park provides the most practicable location. Its position has been selected by considering its potential visual impact not only on Woodhouse Farm, but on other nearby residential properties such as Herring s Farm, Deeks Cottage and Haywards. In addition, further consideration has been given to the future operational requirements of Bradwell Quarry as it moves in an easterly direction across the airfield and the potential alignment of the proposed A120 (The preferred alignment of the proposed A120 is unknown; historically an option has been presented whereby the A120 crossed Rivenhall Airfield along the southern boundary of Bradwell Quarry, adjacent to Woodhouse Farm). It should be noted that further screening and mitigation measures will be implemented whereby the existing tree and hedgeline which runs along the northern boundary of Woodhouse Farm will be reinforced with further planting. Furthermore, the ecological environment in and around Woodhouse Farm will be improved and maintained through the implementation of a woodland management plan. Existing trees and structures will be managed and maintained to provide suitable habitats for the existing reptiles, birds and mammals.

62 December The setting and local environment in and around Woodhouse Farm will remain largely unchanged and unaltered. The approach to Woodhouse Farm and view from the farmhouse will be largely screened from the ercf by areas of existing woodland, planting and vegetation. It should be noted that by incorporating Woodhouse Farm into the ercf development proposals, derelict Grade II listed buildings will be redeveloped and brought into beneficial use and made available to the public. By so doing, the ecological and historical environment at Woodhouse Farm will be improved through the introduction of woodland and water management schemes, and the careful clearance of overgrown vegetation to allow visitors to use the farm and view the buildings, moat and local historic finds Cultural Heritage The following information is intended to address and clarify the comments raised by the ECC Built Environment within their consultation response of 6 November 2008 to ECC and the subsequent Regulation 19 Request for additional information presented within Appendix Woodhouse Farm Cottage An assessment of the Ordnance Survey historical mapping indicates that a building was erected on the site of Woodhouse Farm Cottage (located to the north of Woodhouse Farm) in the period 1875 to A building is not shown on the :2500 scale OS map; however, one is presented on the later :2500 scale OS map. Subsequent OS maps illustrate an unchanged layout for this building (i.e. on the OS 1:2500 scale maps of , 1939, ) and therefore it is considered that the building present on-site today is the same building erected in the period 1875 to (The internal layout and fabric of the building also suggests it was constructed within this period.) Planning Policy Guidance 15 (PPG 15): Planning and the Historical Environment provides guidance on curtilage structures. Paragraph (3.33) of PPG 15 states: The listing of a building confers protection also on any object or structure within its curtilage which forms part of the land and has done so since before 1 July Woodhouse Farm Cottage was constructed before 1 July Therefore, the following additional information is presented to determine whether it forms part of the curtilage of the listed buildings of Woodhouse Farm. Paragraph (3.34) of PPG 15, which states: The principal tests as to whether an object or structure is within the curtilage of a listed building relate to the physical layout of the land surrounding the listed buildings at the date of the statutory listing and the relationship of the structures on the surrounding land to each other The Courts have held that for a structure or building within the curtilage of a listed building to be part

63 December of a listed building it must be ancillary to the principal building, that is it must have served the purposes of the principal building at the date of listing, or at a recent time before the date of listing, in a necessary or reasonably useful way and must not be historically an independent building. Where a self-contained building was fenced or walled-off from the remainder of the site at the date of listing, regardless of the purpose for which it was erected and is occupied, it is likely to be regarded as having a separate curtilage. The structure or building must still form part of the land, and this probably means that there must be some degree of physical annexation to the land. Paragraph (3.36) of PPG 15 provides some precautionary advice and states: It is always necessary to recognise, however, that the question of whether a building, or structure or object is within the curtilage of, or is fixed to, the principal building, unless specifically included in the listing, is in any particular case a matter of fact and ultimately a matter for the Courts. Great caution must, therefore, be exercised in attempting to extrapolate any general principles from recent decisions and this guidance does not purport to be definitive. During the construction of Woodhouse Farm Cottage between 1875 and 1897 within the boundaries of Woodhouse Farm s moat, a footbridge was constructed to provide access to the Cottage. The footbridge is located on the across the western side of the moat. In addition, it should be noted that Woodhouse Farm Cottage was fenced off from the remainder of the Woodhouse Farm. The listing of Woodhouse Farm, The Bakehouse and the hand pump are all dated to 18 May Woodhouse Farm Cottage was not listed (at this or any other time since) and is not mentioned in the listing descriptions for these structures. Therefore, it is likely that the Cottage was considered to be a self-contained building in a fenced off area, separate from the remainder of the Woodhouse Farm. Refurbishment, improvement and redevelopment works in and around Woodhouse Farm will include Woodhouse Farm Cottage. At this stage it is considered that the restoration work to the Cottage will not require Listed Building Consent because it is considered to be outside the curtilage of the principal listed buildings. However, it should be noted that any refurbishment, improvement and redevelopment works will be investigated, reviewed, appraised and agreed with the local District Authority when applying for the listed building consent for Woodhouse Farm, The Bakehouse and the hand pump. It is acknowledged that Woodhouse Farm Cottages will be integral part of the proposed ercf s Visitor and Education Centre, therefore any improvement works will take into account the overall master planning of Woodhouse Farm and the requirements of the Grade II listed structures.

64 December Removal of the Existing Hangar With reference to the Construction and Operations Assessment, the hangar which is located on the Site is neither listed nor scheduled. English Heritage recently published a list of newly listed World War II airfields and Rivenhall was not identified as one where there is a case for preservation. However, in advance of any works across the Site, archaeologists will be given the opportunity to visit the Site to take photographic records of the hangar, loop hardstandings and associated buildings. Thereafter, the hangar will be dismantled and relocated to an alternative site where it could be reassembled for reuse, or otherwise recycled Rights of Way It is confirmed that a short diversion of Footpath 56 could be implemented through legal agreement to provide one single crossing point across the existing site access road. This would address the existing anomaly associated with the linkage of the footpaths and minimise conflict between the road, the footpath and the bridleway network. During the course of the refurbishment, improvement and redevelopment works to Woodhouse Farm it may be necessary to seek appropriate orders for the temporary diversion of Footpath 8. The timing and need for this diversion will be largely dependent upon the scale of the works required to the derelict Grade II listed buildings. However, the existing rights of way will remain open and available for as long as possible; if necessary, footpath 8 will be temporarily diverted around the eastern edges of Woodhouse Farm and the existing moat. Following the refurbishment, improvement and redevelopment works to Woodhouse Farm, Footpath 8 will be reinstated to its original line.

65 December Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf FIGURES

66 December Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf APPENDICES

67 December Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf APPENDIX 19-1 ESSEX COUNTY COUNCIL, REGULATION 19 REQUEST FOR ADDITIONAL INFORMATION

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74 December Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf APPENDIX 19-2 EDF ENERGY NETWORK DISTRIBUTION

75 BARKING WEST BARKING WEST 5. WARNERS END 6. FROGMORE 7. KINGS LANGLEY 1. WATER LANE LINK 2. HARTSPRINGS 3. MERRY HILL 4. BERRY GROVE RICKMANSWORTH WATFORD SOUTH EASTCOTE OPERATING AT 33kV HOLYWELL PINNER GREEN TO IVER LINDSEY ST WESTBURY SOUTH RUISLIP CROWLANDS SELINAS LANE CHERRY TREE BECONTREE HATCH END HARROW BUSHEY MILL GROVE MILL LANE S HARROW SUDBURY COURT EPPING GRID ROMFORD NORTH CHASE CROSS OP AT 11kV BARKING SOUTH ESSEX PICCOTTS END OP. AT 33kV NORTH HARROW 5 6 ST. PAUL S 7 INDUSTRIAL ABBOTTS CENTRAL HEMEL NORTH HEMEL EAST 1 2 GREEN -HILL KENTON ADELAIDE ST WEALDSTONE NORTH LONDON 3 NOAK HILL 4 WATFORD G.E.C. COLINDALE STRAIGHT ROAD OPERATING AT 11kV PARK ST POWER STN MARSHALSWICK CELL BARNES STANMORE HENDON KINGS BURY CENT. WEMBLEY B.E.E. BERESFORD AVE. HAROLD WOOD GIDEA PARK ROMFORD M. & B. CHEQUERS FORDS MANOR WAY RAINHAM gen. GRAHAM PARK ONGAR OPERATING AT 33kV ELM PARK RAINHAM PURFLEET SHENLEY MANNS R WILLESDEN SHENFIELD WEST THURROCK ELSTREE HIGH ST ELSTREE STONE GR MILL HILL TUNNEL CHURCH END BELLE VUE HENDON WAY GOLDERS GRN INGATESTONE MILL HILL HUTTON BRENTWOOD HORNCHURCH LAKESIDE HATFIELD BROCKEN -HURST LITTLE BELHUS SOMERS HEATH ROWLEY LN CRANHAM HEDLEY AVENUE WHETSTONE CROUCH END CENTRAL WELWYN N FINCHLEY FINCHLEY LEICESTER ROAD HATFIELD WEST POTTERS BAR WEST CHELMSFORD WEST HORNDON BARCLAY WAY WARLEY MARSH FOOT GRAYS OP. AT 11kV SELWYN ROAD P.L.A. TILBURY LOCAL WELWYN CRANLEY GDNS E BARNET E FINCHLEY CHANTRY LANE CENTRAL POTTERS BAR TAPSTER ST WATSONS RD COCKFOSTERS HORNSEY WRITTLE ST SOUTH CHELMSFORD GOOSEBERRY GREEN BILLERICAY EAST WEST HERTFORD CUFFLEY HODDESDON N. ENFIELD LADYSMITH ROAD LONSDALE DRIVE BURY ST NEVENDON FORDS TRACTOR FORDS DUNTON TILBURY LOCAL LIMES BASILDON RAINBOW LANE BARNET WEST GREEN EAST HERTFORD RYE HOUSE PALMERS GREEN BRUCE GROVE CENTRAL TOTTENHAM CHELMSFORD EAST WEST HANNINGFIELD DURHAM ROAD KINGSWOOD SHELL S/S 14 BATA LEEMANS TILBURY MSD WICKFORD GLAXO BRIMSDOWN BROXBOURNE TURNFORD E. ENFIELD PONDERS END GARDNERS LN CEN. EDM NT N CHALVEDON BASILDON LOCAL SHELL edl gen.mucking WARE TOTTENHAM CORYTON RAYLEIGH THUNDERSLEY U.K. PIPELINES SHELL POWER HOUSE THE CROSS BRIMSDOWN SOUTH EDMONTON TO ST. PS JOHN S WOOD TO HACKNEY DANBURY WALTHAM CROSS WALTHAM ABBEY TO REDBRIDGE SOUTH WOODHAM FERRERS RAYLEIGH MAIN/LOCAL SOUTH BENFLEET CANVEY MOBIL HADLEIGH UPLANDS PARK BELLH SE LANE HARLOW WEST NORTH CHINGFORD SOUTH CHINGFORD LEIGH MALDON MALDON WICK MALDON CAUSEWAY SOUTHEND WEST SOUTHEND WADDESDON ILMER LUCY THAME TO COWLEY MAIN AVENUE EKCO BUCKINGHAM ROAD BOC THAME CHINNOR OPERATING AT 132kV PRITTLEWELL (RAILWAY) (* SUNDON - LUTON N 132kV ONE CIRCUIT OP. AT 33kV) TO EAST CLAYDON EXCHANGE ST. NORTH DRIVE BURNHAM FLEETHALL THORPE BAY HOUGHTON REGIS AYLESBURY EAST SAUNDERTON LINKED CIRCUITS TO GRENDON GT. MISSENDEN BURNHAM SWITCHING STATION A.W.R.E. PREBEND STREET LEIGHTON BUZZARD WENDOVER TILLINGHAM BROGBOROUGH POWER STATION BROGBOROUGH SUNDON DUNSTABLE KENSWORTH TRING CHEDDINGTON BERKHAMSTED BOIS LANE TO STAMFORD TO CORBY R.A.E. CADDINGTON AMERSHAM LYE GREEN A.R.A MANTON LANE BRINGTON HARROWDEN STEWARTBY MARSTON ROAD AMPTHILL TO COTTAM PETERBOROUGH NORTH PETERBOROUGH CENTRAL PETERBOROUGH SOUTH CENTRAL NETWORKS (EAST) TO GRENDON PITSTONE CEMENT WALPOLE ST.ANDREW SUNDON EATON SOCON EDISON RD BEDFORD BARTON CH.E. FARCET WOODWALTON LUTON S RAF ALCONBURY PERRY SANDY AUSTIN CANONS OP AT 11kV SKF. LEWSEY BUSHEY MILL HOLYWELL BIGGLESWADE STOPSLEY CENTRAL HARPENDEN SHEFFORD LETCHWORTH FACTORY NORTH HITCHIN SOUTH HITCHIN OP AT 33kV TILNEY ALL STS WALPOLE KIMBOLTON BRETTON ORTON WESTONING CAPABILITY GREEN PICCOTTS END KINGS LYNN OPERATING AT 11kV TO BOURNE KINGS LYNN SOUTH LUTON N LUTON ST.MARY S AIRPORT WARREN SPRGS VAUXHALL HAYWARD TYLERS OFFORD LYLE EAST HARPENDEN CELL BARNES KINGS LYNN ELSTREE PETERBOROUGH EAST OLD WELWYN WIGGENHALL POWER STATION W. LETCHWORTH E. LETCHWORTH OPERATING AT 11kV WHITTLESEY BURY HUNTINGDON GODMANCHESTER LT BARFORD HATFIELD HARDWICK RD FUNTHAMS LANE BOURN SOUTH STEVENAGE EAST STEVENAGE KNEBWORTH CROYDON CENTRAL WELWYN ST. IVES BASSINGBOURN LETCHW TH WYMONDLEY STEVENAGE WELWYN KINGS LYNN GAYWOOD FAIRSTEAD HILTON EST PETERBOROUGH POWER STATION VERITY WAY WEST GUYHIRN LEVERINGTON WISBECH RAILWAY MARCH HISTON CHATTERIS ALDRETH MADINGLEY RD STOREYS WAY THOMPSONS LANE SLEAFORD STREET ROYSTON NORTH STEVENAGE TO WEST BURTON SHEPRETH ST. ANTHONY MELBOURN CHERRY S GRN RYE HOUSE WALTHAM CROSS TO BOURNE LONGSTANTON REED MUCH HADAM HARLOW WEST WALPOLE MARCH sutton power stn. STICKFAST LANE LANDBEACH STREET PELHAM MILTON SAWSTON THORLEY OUTWELL TILNEY ALL STS LAKES END RADNOR ELY HANGER LEA NEW TOWN LITTLEPORT BARNWELL HARDWICK RD OPERATING AT 11kV WIGGENHALL WALSOKEN FULBOURN SAFFRON WALDEN ACROWS THAXTED BISHOP S STORTFORD NORTH HARLOW SOUTH HARLOW OPERATING AT 33kV MILTON RD HISTON ADDENBROOKES EPPING GRID KINGS LYNN STANSTEAD SOUTH AUX KINGS LYNN POWER STATION TAKELEY WISSINGTON BEET FACTORY LINTON UGLEY SOHAM DUNMOW WHITE RODING KINGS LYNN GAYWOOD DOWNHAM MARKET SOUTHERY EXNING NEWMARKET FAIRSTEAD EST FELTWELL LAKENHEATH MILDENHALL BURWELL WRATTING HAVERHILL HUNSTANTON SNETTISHAM MARHAM ICKLINGHAM KENNETT WIXOE PUMPING STATION CHELMSFORD NORTH OP. AT 11kV BRAINTREE WEST WETHERSFIELD BRAINTREE NARBOROUGH NORTHWOLD BRAINTREE DEPOT BRANDON FORNHAM COXFORD LT. MASSINGHAM BARROW BELCHAMP LAKE & ELLIOT CHELMSFORD EAST THETFORD PLAYFIELDS BURY ST EDMUNDS HALSTEAD WITHAM BOXTED BURNHAM THORPE THETFORD WATER LANE THETFORD KIMMS BELT HONINGTON KEMPSTONE SWAFFHAM GLEMSFORD SUDBURY GT. CORNARD COGGESHALL MARKS TEY TIPTREE FAKENHAM HEMPTON EAST DEREHAM WATTON THETFORD POWER STATION BRITISH SUGAR POWER STN. OPERATING AT 11kV STANTON DRINKSTONE GROTON BRAISWICK COLCHESTER MALDON EGMERE ELMSWELL SHRUB END OPERATING AT 132kV LEXDEN STODY HARDINGHAM ELLINGHAM ATTLEBOROUGH KENNINGHALL HITCHAM BRAMFORD MANGANESE BRONZE severalls GUSFORD HALL HADLEIGH LANGHAM EAST BAY RICKINGHALL BRANTHAM MERSEA RD PELDON SALL WESTON LONGVILLE WYMONDHAM COTTON IPSWICH PARSONS HEATH BERECHURCH TIVETSHALL DISS ALRESFORD ABBERTON FOXASH BRADWELL CHISBON HEATH W. BECKHAM HAPTON TATTINGSTONE EYE WIX AYLSHAM GT WITCHINGHAM DEBENHAM STOWMARKET LAWFORD EYE HIGHFIELDS TURRET LN BELSTEAD EARLHAM LONG STRATTON GENERATION HORSFORD TO BE COMMISSIONED IN 2004 HARLESTON CLAYDON CEMENT NACTON SHOTLEY CROMER SCOTTOW LAXFIELD ROUNDWOOD ROAD WARREN HEATH CLIFF QUAY FRINTON DOVERCOURT VALLEYBRIDGE ROAD OLD ROAD NORWICH MAIN OP. AT 11kV WICKHAM MARKET NORTH WALSHAM MANOR ROAD MARTLESHAM CLACTON 1. BOUNDARY PARK 2. EARLHAM WEST 3. CRINGLEFORD 4. TUCKSWOOD 5. ST. STEPHENS 6. LS & E 7. BARRACK ST. 8. GEORGE HILL 9. MOUSEHOLD 10. SPROWSTON 11. ALPINGTON 12. MULBARTON KNAPTON WORSTEAD WROXHAM HEMBLINGTON NORWICH THORPE fore hamlet 13. PEACHMAN WAY LODDON STALHAM NORWICH TROWSE OP. AT 11kV ILKETSHALL BUNGAY RUMBURGH FRAMLINGHAM MELTON HACHESTON BENTWATERS LANGLEY AVE DOCK ROAD FAGBURY ROAD OYSTERBED ROAD PEASENHALL BENHALL BEIGHTON MARTHAM ORMESBY BECCLES CAISTER MAGDALEN WAY HALESWORTH ORFORD (FELIXSTOWE) BARSHAM LEISTON HENSTEAD REYDON SIZEWELL KEY 400kV OR 275kV SUBSTATION 132kV SUBSTATION 132kV GENERATING SUBSTATION 33kV SUBSTATION 33kV GENERATING SUBSTATION 400kV OVERHEAD LINE 275kV OVERHEAD LINE 275kV UNDERGROUND CABLE 132kV OVERHEAD LINE 132kV UNDERGROUND CABLE 33kV CIRCUIT 1 EARLHAM NORWICH TROWSE NORWICH MAIN NORWICH OPERATING AT 11kV GT.YARMOUTH GT.YARMOUTH power stn. GORLESTON BRADWELL 13 NORWICH THORPE TO BE COMMISSIONED IN SCROBY SANDS OPERATING AT 11kV WHAPLOAD ROAD LOWESTOFT LOWESTOFT LONG ROAD TO HIGH WYCOMBE SCOTTISH & SOUTHERN AMERSHAM MAIN RICKMANSWORTH TO IVER WATFORD SOUTH TO IVER HATCH END OPERATING AT 33kV WATFORD POWER STANMORE STN GRAHAM PARK HENDON HARROW COLINDALE BARNET MILL HILL FINCHLEY PALMERS GREEN HORNSEY BRIMSDOWN BRIMSDOWN SOUTH TOTTENHAM CROWLANDS SHENFIELD OPERATING AT 33kV HORNCHURCH WARLEY NEVENDON BASILDON RAYLEIGH MAIN/LOCAL SOUTH BENFLEET SOUTHEND FLEETHALL EPN DISTRIBUTION BOUNDARY COASTLINE A Issue Date ORIGINAL Revision -- KAJ C.A.F. Drn. App. LEICESTER ROAD BARKING SHELL CORYTON WILLESDEN PURFLEET WEST THURROCK TILBURY LOCAL TILBURY AREA OF EPN DISTRIBUTION 400KV, 275KV, 132KV AND EDF ENERGY (L.P.N.) SCALE DRAWING NO. 33KV SYSTEMS 1:250,000 (A0) C.A.F. -- ISSUE HQ/2000/3850 A SITE GENERAL Copyright owned by EDF ENERGY. This drawing may not be used or copied without written consent.

76 EARLHAM OPERATING AT 33kV EPPING GRID CHELMSFORD EAST MALDON NORWICH THORPE OPERATING AT 132kV TO BE COMMISSIONED IN 2004 NORWICH TROWSE SHENFIELD KINGS LYNN SOUTH HEMPTON NORWICH MAIN NORWICH CROWLANDS NEVENDON FLEETHALL TO WEST BURTON TO BOURNE WALPOLE KINGS LYNN SALL BARKING OPERATING AT 33kV HORNCHURCH WARLEY BASILDON SHELL RAYLEIGH MAIN/LOCAL SOUTH BENFLEET CORYTON SOUTHEND PETERBOROUGH NORTH PETERBOROUGH CENTRAL TO STAMFORD TO COTTAM TO BOURNE BRETTON PETERBOROUGH EAST PETERBOROUGH POWER STATION WEST MARCH WALSOKEN MARCH KINGS LYNN POWER STATION SWAFFHAM EARLHAM NORWICH MAIN TO BE COMMISSIONED IN 2004 NORWICH THORPE NORWICH TROWSE GT.YARMOUTH GT.YARMOUTH power stn. GORLESTON PURFLEET WEST THURROCK ILKETSHALL LOWESTOFT TILBURY CENTRAL NETWORKS (EAST) SOUTH ESSEX TILBURY LOCAL TO CORBY THETFORD DISS RUMBURGH HUNTINGDON HALESWORTH PICCOTTS END CELL BARNES WELWYN HATFIELD RYE HOUSE HARLOW WEST EATON SOCON HISTON MILTON BURWELL BURY ST EDMUNDS WICKHAM MARKET SIZEWELL R.A.E. LT BARFORD BUSHEY MILL ELSTREE WALTHAM CROSS TO GRENDON TO GRENDON A.R.A. FULBOURN STOWMARKET RICKMANSWORTH HOLYWELL BARNET BRIMSDOWN EDISON BEDFORD ROAD AUSTIN CANONS MELBOURN BELCHAMP BRAMFORD IPSWICH WATFORD WEST WATFORD SOUTH TO IVER HATCH END OP. AT 33kV HARROW WATFORD POWER STN GRAHAM PARK STANMORE HENDON COLINDALE MILL HILL FINCHLEY PALMERS GREEN BRIMSDOWN SOUTH TOTTENHAM TO EAST CLAYDON SUNDON LETCHWORTH WESTONING WYMONDLEY LUTON N PELHAM THAXTED UGLEY COLCHESTER LAWFORD CLIFF QUAY NORTH LONDON LEICESTER ROAD WILLESDEN HORNSEY TO ST. JOHN S WOOD TO HACKNEY TO REDBRIDGE ILMER HOUGHTON REGIS AYLESBURY EAST PICCOTTS END LYE GREEN LUTON S OP AT 33kV WELWYN CELL HATFIELD BARNES STEVENAGE RYE HOUSE HARLOW WEST OPERATING BRAINTREE BISHOP S STORTFORD CHELMSFORD NORTH EPPING GRID CHELMSFORD EAST MALDON OPERATING AT 132kV ABBERTON BRADWELL CLACTON KEY 400kV OR 275kV SUBSTATION 132kV SUBSTATION 132kV GENERATING SUBSTATION 400kV OVERHEAD LINE 275kV OVERHEAD LINE 275kV UNDERGROUND CABLE TO COWLEY MAIN BUSHEY MILL ELSTREE WALTHAM CROSS AT 33kV 132kV OVERHEAD LINE HOLYWELL 132kV UNDERGROUND CABLE TO HIGH WYCOMBE SCOTTISH & SOUTHERN AMERSHAM MAIN RICKMANSWORTH TO IVER WATFORD SOUTH TO IVER HATCH END OPERATING AT 33kV WATFORD POWER STANMORE STN GRAHAM PARK HENDON HARROW COLINDALE BARNET MILL HILL FINCHLEY PALMERS GREEN BRIMSDOWN BRIMSDOWN SOUTH TOTTENHAM CROWLANDS SHENFIELD OPERATING AT 33kV HORNCHURCH NEVENDON BASILDON RAYLEIGH MAIN/LOCAL FLEETHALL TXU EUROPE DISTRIBUTION BOUNDARY COASTLINE A ORIGINAL -- KAJ HORNSEY WARLEY SOUTH BENFLEET SOUTHEND Issue Date Revision C.A.F. Drn. App. LEICESTER ROAD BARKING SHELL CORYTON WILLESDEN PURFLEET WEST THURROCK TILBURY LOCAL TILBURY AREA OF EPN DISTRIBUTION 400KV, 275KV, 132KV AND EDF ENERGY (L.P.N.) SCALE DRAWING NO. 33KV SYSTEMS 1:250,000 (A0) C.A.F. -- ISSUE HQ/2000/3850 A SITE GENERAL Copyright owned by EDF ENERGY. This drawing may not be used or copied without written consent.

77 December Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf APPENDIX 19-3 BLACKWATER AGGREGATES EXPRESSION OF INTEREST

78

79 December Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf APPENDIX 19-4 ADDITIONAL TEMPRO/NRTF CALCULATIONS

80 Factors for different time periods (Braintree rural zone) NRTF Table 3 Rates: Enter the figures in red Type of Road : 4 (Rural other) Factor in 2005 = Factor in 2018 = Factor from 2005 to 2018 = TEMPRO Factors AM peak Local Factor from 2005 to 2018 = 'Av. Day' GB Factor from 2005 to 2018 = PM peak Local Factor from 2005 to 2018 = 'Av. Day' GB Factor from 2005 to 2018 = Saturday Local Factor from 2005 to 2018 = 'Av. Day' GB Factor from 2005 to 2018 = Overall Traffic Growth AM Factor from 2005 to 2018 = PM Factor from 2005 to 2018 = Saturday Factor from 2005 to 2018 =

81 Factors for different time periods (Braintree rural zone) NRTF Table 3 Rates: Enter the figures in red Type of Road : 4 (Rural other) Factor in 2006 = Factor in 2018 = Factor from 2006 to 2018 = TEMPRO Factors AM peak Local Factor from 2006 to 2018 = 'Av. Day' GB Factor from 2006 to 2018 = PM peak Local Factor from 2006 to 2018 = 'Av. Day' GB Factor from 2006 to 2018 = Saturday Local Factor from 2006 to 2018 = 'Av. Day' GB Factor from 2006 to 2018 = Overall Traffic Growth AM Factor from 2006 to 2018 = PM Factor from 2006 to 2018 = Saturday Factor from 2006 to 2018 =

82 December Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf APPENDIX 19-5 PREDICTED ercf TRAFFIC FLOWS

83 Existing HWRCs (Household Waste Recycling Centres) Under Essex County Council Authority Preferred Sites for Waste Management 1 - WM1 - Rivenhall Airfield (Gent Fairhead & Co. Limited), Woodhouse Farm, Rivenhall Airfield, Rivenhall, Braintree 1 - Civic Amenity & Recycling Centre - Braintree District Council, Braintree Road, Shalford CM7 5HQ WM2 - Stanway, Warren Lane, Stanway, Colchester, Essex CO3 5NN 2 - Civic Amenity & Recycling Centre - Braintree District Council, Perry Road, Witham CM8 3YY 3 - WM5 - Basildon (Essex County Council), Courtauld Road, Basildon SS13 1DB 3 - Civic Amenity & Recycling Centre - Chelmsford Borough Council, Drovers Way, Boreham, Chelmsford CM2 5PP 4 - WM6 - Sandon, Sandon Quarry, Hall Lane East, Southend Road, Sandon CM2 7AD 4 - Civic Amenity & Recycling Centre - Chelmsford Borough Council, Ferrers Road, South Woodham Ferrers CM3 5XH 5 - Civic Amenity & Recycling Centre - Colchester Borough Council, Maldon Road, Shrub End, Colchester CO3 4RN Composting Sites Civic Amenity & Recycling Centre - Colchester Borough Council, Upland Road, West Mersea CO5 8DX Rainham Compost Site - Cleanaway Ltd., Coldharbour Lane (off Ferry Lane), Rainham RM13 9DA 7 - Civic Amenity & Recycling Centre - Epping Forest District Council, Luxborough Lane, Chigwell IG7 5AA 2 - Pitsea Compost Site - Cleanaway Ltd., Pitsea Hall Lane, Pitsea SS16 4UH 8 - Civic Amenity & Recycling Centre - Epping Forest District Council, Mill Lane, High Ongar Great Totham Compost Site - Appleton Contracts, Loamylands, Loamy Hill Road, Tolleshunt Major, Maldon, Essex, CM9 8LS Civic Amenity & Recycling Centre - Harlow District Council, Temple Bar, River Way, Harlow CM20 2DW 4 - Birch Compost Site - J.F & C.M Strathern, Park House Farm, Layer Marney, Colchester, Essex CO5 9UH Civic Amenity & Recycling Centre - Colchester Borough Council, Maldon Road, Shrub End, Colchester CO3 4RN 10 - Civic Amenity & Recycling Centre - Maldon District Council, Springfield Road, Burnham-On-Crouch CM0 8UA Civic Amenity & Recycling Centre - Maldon District Council, Park Drive, Maldon CM9 5JQ Ipswich Compost Site - Viridor Waste Management, Foxhall Rd, Brightwell, Ipswich IP10 0HT Civic Amenity & Recycling Centre - Tendring District Council, West End Lane, Dovercourt CO12 3TA 7 - Ipswich Compost Site - County Mulch Ltd., The Watering Farm, Creeting St Mary, Ipswich IP6 8ND Ipswich Compost Site - CDV, Cliff Quay Treatment Works, Raeburn Road South, Ipswich IP3 0ET Civic Amenity & Recycling Centre - Tendring District Council, Maltings Lane, Kirby-Le-Soken CO12 0EH Ongar Compost Site - Heatherlands Ltd., Hallsford Bridge Industrial Estate, Stonden Road, Ongar CM5 9RB 14 - Civic Amenity & Recycling Centre - Tendring District Council, Greensmill, Lawford CO11 1UW Civic Amenity & Recycling Centre - Tendring District Council, Martins Farm, Colchester Road, St Osyth CO16 8EH Landfill Sites Civic Amenity & Recycling Centre - Tendring District Council, Rush Green, Clacton CO16 7BG Stanway Landfill Site - Cory Environmental Waste Management, Warren Lane, Stanway, Colchester CO3 5NN Pitsea Landfill Site - Cleanaway Ltd., Pitsea Hall Lane, Pitsea SS16 4UH 17 - Civic Amenity & Recycling Centre - Uttlesford District Council, Thaxted Road, Saffron Waldon CB10 2JP Civic Amenity & Recycling Centre - Basildon District Council, Pitsea Hall Road, Pitsea SS16 4UH Ockendon Landfill Site - Cleanaway Ltd., Medebridge Road, South Ockendon, Grays RM16 5TZ 19 - Civic Amenity & Recycling Centre - Brentwood District Council, Coxtie Green Road, Brentwood CM14 5PN Ugley Landfill Site - Biffa, Cambridge Road, Ugley, Bishops Stortford CM22 6HT 20 - Civic Amenity & Recycling Centre - Brentwood Borough Council, Roman Road, Mountnessing Barling Landfill Site - Cory Environmental Waste Management, Southend Road, Great Wakerley, Southend-On Sea SS3 0PU Civic Amenity & Recycling Centre - Castlepoint Borough Council, Canvey Road, Canvey Island SS8 0QX 6 - Elsenham Landfill Site - Viridor Waste Management, Hall Road, Elsenham, Bishops Stortford CM22 6DJ Little Canfield Landfill Site - Edwards Waste Management, Crumps Farm, Stortford Road, Little Canfield CM6 1SR 23 - Civic Amenity & Recycling Centre - Rochford District Council, Castle Road, Rayleigh SS6 7QF 7 Transfer Stations 3 23 Proposed HWRCs (Household Waste Recycling Centres) Under Essex County Council Authority Braintree Depot - Braintree District Council, Unit 3 Lakeside Industrial Park, Braintree CM7 3RV Cordons Farm - Braintree District Council, Long Green Ashes Road, Braintree CM77 8DL Civic Amenity & Recycling Centre - Uttlesford District Council, Hoblings Industrial Estate, Chelmsford Road, Great Dunmow CM6 1JA Civic Amenity & Recycling Centre - Braintree District Council, Sible Hedingham Chelmsford Transfer Station - Chelmsford Borough Council, Waltham Road, Boreham, Chelmsford CM3 5NT Shrub End Depot - Colchester Borough Council, Shrub End, Colchester CO3 3RN 5 - Eastern Waste Disposal Ltd, Morses Lane, Brightlingsea, Colchester CO7 0SD 22 - Civic Amenity & Recycling Centre - Epping Forest District Council, Town Mead, Brooker Road, Waltham Abbey EN9 1DP 10 Existing HWRCs (Household Waste Recycling Centres) Under Southend-On-Sea Borough Council Authority 1 - Civic Amenity & Recycling Centre - Southend-On Sea Borough Council, Stock Road, Prittlewell SS2 5QF Edwards Waste Management Ltd, Barnfield, Epping Rd, Roydon, Harlow CM19 5DP 2 - Civic Amenity & Recycling Centre - Southend-On Sea Borough Council, Two Tree Island, Leigh-On-Sea SS9 2ET 7 - Harwich Reclaim Riverside, Harwich Industrial Estate, Europa Way, Parkeston, Harwich CO12 4PT Key Essex County Boundary MRFs (Material Reclamation Facilities) Essex County Council Authority 1 - Chelmsford MRF - Chelmsford Borough Council, Drovers Way, Boreham, Chelmsford CM2 5PP Thurrock District Council Authority Southend-On-Sea Borough Council Authority 2 - Rainham MRF - Cleanaway Ltd., Coldharbour Lane (off Ferry Lane), Rainham RM13 9DA 3 - Crayford MRF - Grosvenor Waste Management, Century Wharf, Crayford Creek, Crayford DA1 4QG 4 - Boreham MRF - S B Wheeler, Unit 15, Boreham Industrial Estate, Waltham Road, Boreham, Chelmsford CM3 3AW Date Project No Created by C.N. File No Title Waste Management & Recycling Facilities In Essex Rivenhall Airfield Figure 1

84

85 Regulation 19 - Additional Information - ercf Movement Summary Summary of Inbound Waste HGV Vehicle Movements ercf Incoming Daily Vehicle Movements ( In full, Out empty) Per Day ercf Daily Import Total Tonnage Days/yr Tonnes per day Vehicle payload One Way Movements Municipal Solid Waste Mixed Dry Recyclables Mixed Organic Waste Solid Recovered Fuel Mixed Paper & Card Total District Collections, RCHWs, C&I, SRF & Paper Import Summary Authority A120 MSW MDR Compost Mixed Paper SRF Braintree Eastbound Epping Forest (50%) Eastbound Harlow Eastbound Uttlesford Eastbound Chelmsford Eastbound Colchester Westbound Maldon Westbound Tendring Westbound RCHWs North Essex Eastbound Import from RCHWs Eastbound Westbound Import from RCHWs Westbound C&I Imports Balancing C&I Imports East & West SRF & Paper Imports Mixed Paper & Card East & West Solid Recovered Fuel East & West Total Eastbound Import along A120 Eastbound Eastbound No. of Eastbound HGV Movements per day Eastbound % Total Westbound Import along A120 Westbound Westbound No. of Westbound HGV Movements per day Westbound % TOTAL East & West No of HGV Movements per day East & West Notes: Balancing C&I, SRF and Paper imports to the ercf: 57.5% Eastbound & 42.5%Westbound Split Summary of RCHW operations in North Essex COMPOST MDR MSW Direct to Transfer Station Site Name, Location A120 Green Paper & Card Plastics Landfill Waste Glass Textile & Shoes Cans & Scrap Fridges CRTs Car Batteries Tyres Ceramics Engine Oil Timber Shalford, Braintree Eastbound Witham, Braintree Eastbound Ongar, Epping Eastbound Harlow, Harlow Eastbound Saffron Waldon, Uttlesford Eastbound Boreham, Chelmsford Westbound S Woodham, Chelmsford Westbound Colchester, Colchester Westbound West Mersea, Colchester Westbound Burnham, Maldon Westbound Maldon, Maldon Westbound St Osyth, Tendring Westbound Dovercourt, Tendring Westbound Kirby, Tendring Westbound Clacton, Tendring Westbound Lawford, Tendring Westbound Total Waste Available to ercf Total Import to ercf Note: It is considered that 35% of the MSW from the RCHW will be exported directly to landfill Summary of Outbound Recyclate & Residue HGV Vehicle Movements ercf Outgoing Daily Vehicle Movements (In empty, Out full) Per Day ercf Daily Export Total Tonnage Days/yr Tonnes per day Vehicle Payload One Way Movements Landfillable rejects from MBT & MRF Recyclables (3 streams) Ashes & Residues (2 streams) Recycled Paper Pulp Total ercf Export Summary HGV access to ercf Eastbound Westbound Material Landfillable rejects from MBT & MRF 4 3 Recyclables (3 streams) 10 6 Ashes & Residues (2 streams) 6 6 Recycled Paper Pulp Total Summary 58% 42% Notes: A genuine pre-estimate of the likely export destinations has been applied considering potential export destinations such as landfills, reprocessors and paper mill locations. ercf Movements Along A120 ercf Incoming HGV Movements ( In full, Out empty) ercf Outgoing HGV Movements (In empty, Out full) Eastbound Westbound 57.25% 42.75% 58% 42% 57.5% 42.5%

86 December Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf APPENDIX 19-6 STORM WATER RUN-OFF CALCULATIONS

87 IOH 124 SITE NAME LOCATION Rivenhall Airfield Coggeshall, Essex Parmeter Unit Value GrowthFactor (100 years) Comments QBARrural Descriptors Descriptors QBARurban Site Area ha 21.5 km Calc Area km SAAR4170 mm 585 SOIL Type 3 Growth Factor Thames Region (6) QBAR rural l/s l/s/ha l/s (Site) cumecs Hardstandng ha 1.5 URBAN CWI 78 CIND 27.8 NC QBAR urban l/s l/s/ha l/s (Site) cumecs Project Number: Date: November 2008 Created by: R Evans

88 Storage Volume Calculations Estimated Site Area 215,000 m 2 Greenfield Discharge Q l/s/ha Post Development 100 year return period surface cover area 215,000 m 2 runoff coefficient 0.95 Volume of Runoff Discharge at Q100 greenfield Total storage required using Q100 greenfield Duration (minutes) Rainfall (mm) (m 3 ) rate (m 3 ) rates (m 3 ) Maximum 10,547 Post development 100 year return period + 30% surface cover area 215,000 m 2 runoff coefficient 0.95 Volume of Runoff Discharge at Q100 greenfield Total storage required using Q100 greenfield Duration (minutes) rainfall (mm) (m 3 ) rate (m 3 ) rates (m 3 ) Maximum 14,413 Project Number: Date: November 2008 Created by: R Evans

89 December Regulation 19 Additional Information Version A.0 Rivenhall Airfield ercf APPENDIX 19-7 RK/PA/03: LANDSCAPING STRATEGY ACCESS ROAD AND BRADWELL PIT NORTH

90