OBJECTION GUIDANCE

We strongly oppose the granting of an Environmental Permit Ref: EPR/QP3720LP/A001 to Fornax (North East) Ltd for their proposed Hazardous and Clinical Waste Incineration Plant in Newton Aycliffe. Our objection is based on serious concerns regarding safety, transparency, and environmental impact. 1. Missing/Misclassified Receptors Fornax’s assessments describe the area as an ‘industrial estate’, not a business park as it known as. Therefore, the Human Health Risk and Air Dispersion Modelling Assessments fail to identify real people and places, i.e. potential receptors including nearby residential areas, early years settings, schools, offices, public spaces, farms, public footpaths, leisure spaces, visitors and those who may reside in future developments. This means the assessment seriously underestimating who will be exposed to harmful emissions and putting public health at risk.    2. Ignoring Cumulative Air Pollution on Aycliffe Business Park and Surrounding Areas: Rather than testing the air in Newton Aycliffe, the company used national pollution averages, which is not a true reflection of what’s happening. Fornax’s assessments ignore existing pollution from nearby industrial sites, busy roads, and factories (notably including Ineos and Emerald Biogas), within their Air Dispersion Modelling Assessment, relying on generic national data instead of real local measurements, failing to consider cumulative pollution impacts, local conditions, wind patterns and putting vulnerable communities at increased health risk.      3. Misleading Modelling Using Domestic Waste Incinerator, not Hazardous The pollution profile within their Human Health Risk Assessment used to assess health risk, particularly dioxins and furans expected, was not based on correct assumptions. The model used was created using figures from an outdated 1996 municipal waste incinerator (household waste) model, not hazardous waste, which makes their pollution models unreliable and leads to dangerously inaccurate assessment of emissions and health risks.      4. Inadequate Stack Height The proposed 30-metre stack height is insufficient to safely disperse harmful emissions, especially given nearby schools and offices, and weather conditions that can trap pollution, posing serious health risks that have not been properly assessed or addressed.      5. Doubts regarding Operator Competence Fornax’s submitted documents including Air Dispersion Modelling Assessment and Fire Prevention Plan show contradictory information, and a lack of site-specific detail. This raises serious doubts about their competence, while limited Environment Agency oversight means the public can’t trust this hazardous waste facility will be properly managed or adequately monitored.     6. Fornax Incinerator Fails to Meet Legal Standards Fornax (North East)’s incinerator permit application fails to meet basic legal requirements for environmental protection, safety, and pollution control. Key problems include Failure to meet Best Available Techniques (BAT) – No clear plan to contain toxic substances from high-risk waste like batteries and WEEE (electronic waste).   7. Insufficient Accident Management The application fails to model or plan for incinerator malfunctions or emergency emissions—putting nearby childcare settings, schools, workplaces, and public areas at risk from toxic pollutants like dioxins and heavy metals in the event of an accident or system failure.       8. Inadequate Fire and Explosion Plan The Fire Prevention Plan lacks site-specific detail and worst-case scenario planning, leaving schools, nurseries, and local businesses unprotected in the event of fire, explosion, or chemical accident, posing unacceptable risk to health, safety, and business continuity.    9. Capacity Loophole The modelling outlined in the application is for 1.2 tonnes per hour, however the permit allows up to 3 tonnes, allowing emissions to increase without proper monitoring or control.      10. Inadequate Emergency Planning No adequate planning for malfunctions or emergency emissions threatens nearby childcare, schools, and public areas. 11. Waste type not permitted Waste types proposed under this environmental permit application are not permitted under the planning consent granted for the site. The Air Dispersion Modelling Assessment models pollution risks but that modelling is based on conflicting waste types – data is unreliable and misleading.    12. Conflict with Planning and Amenity Aycliffe Business Park, which is designated for advanced industry, not hazardous waste, which is why Durham County Council initially refused the application. A hazardous waste incinerator threatens local safety, investment, and community health. How much pollution can one community take?    13. Lack of Public Engagement and Transparency Residents and local businesses have not been given enough clear information, expert support, public consultation or time to fully understand or challenge this complex and technical proposal.     14. No Real Community or Economic Benefit There is no proven benefit to the local community, minimal new jobs, no infrastructure improvements, only harm to nearby businesses and residents.     15. Poor Consideration for Wildlife and Habitats The permit application does not fully assess or protect important natural areas, rare species, and valuable local wildlife habitats. The environmental information provided within their Ecological Appraisal is outdated, inconsistent, and misses key risks, which weakens the reliability of the permit review.  16. Uncontrolled odour risks The permit lacks a clear plan to manage strong smells from clinical and hazardous waste, with no effective odour controls, ventilation strategy, or safeguards against offensive waste being accepted.  17. Inadequate Controls for Complex Waste Streams Fornax proposes to burn over 480 waste types, including asbestos and toxic chemicals, without adequate controls to ensure compliance with the Best Available Techniques relevant to segregation and mixed incineration.