SKM Enviros direct involvement in Norfolk and concerns over base line monitoring.

Accurate base line monitoring is essential for establishing a reference point to measure future increases in air pollution. If particulate PM2.5 is found to be increased in the Urban Air this would be in breach of EU Directive 2008/50/EC and could lead to legal action forcing the (very expensive) closure of the incinerator. Directive 2008/50/EC On ambient air quality and cleaner air for Europe states...
“Fine particulate matter (PM2,5) is responsible for significant negative impacts on human health. Further, there is as yet no identifiable threshold below which PM2,5 would not pose a risk. As such, this pollutant should not be regulated in the same way as other air pollutants. The approach should aim at a general reduction of concentrations in the urban background to ensure that large sections of the population benefit from improved air quality”.

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To provide meaningful base line data the prevailing wind needs to be taken into account and air monitoring equipment located at varying distances downwind of the proposed incinerator, especially in the town of King’s Lynn so compliance with Directive can be checked. If monitoring equipment is not located with due care, it will fail to register increases in air pollution and could make it difficult to determine if air quality has deteriorated from pre-incinerator levels. A freedom of information request has revealed on 11th March 2010 a representative of SKM Enviros held discussions with Council staff regarding base line monitoring. They now have base line monitoring equipment in operation at the only place in West Norfolk where it can be guaranteed not to detect an increase in future air pollution.

Figure 1 is a recent photograph showing monitoring equipment operating at the intended location of the incinerator. Figure 2 is a photograph of an operational incinerator to help illustrate why this location is inappropriate for recording base line air pollution. If an incinerator is constructed with an 8o meter tall stack the purpose of the stack is to disperse the pollution away from the immediate site area. Particulate Matter/emissions do not fall to earth like a stone as they leave the stack thus; it is evident whichever way the wind is blowing air quality at the base of the incinerator will always be free from any significant incinerator emissions whatever concentrations are emitted from the stack. This point is illustrated by the X in a box at the bottom of figure 2 if this was the position of the County Councils’ emissions monitoring equipment it would be completely ineffective. If this location is used to monitor air quality before and after the incinerator is built any figures published will implying the incinerator is not contributing to air pollution.

It will reinforce what the HPA believe to be true. Even if data collected at this location is only used as a contribution to a wider survey, it will bring the average reading down making the emissions appear cleaner than they really are. Figure 3 shows the 10 sites in East Anglia where fine particles PM2.5 are currently being monitored, they are not within the critical 16 mile of the proposed incinerator where the main deposition of fallout can be expected, they also will not provide any meaningful data relating to the incinerator.