Back to our response from our legal letter…….in the Intertek summary document, under the issue heading “air pollution not fully assessed” where the following comments were highlighted:
- pollution from vessels not appropriately assessed
- air pollution modelling should be be applied
There were many more comments made regarding air pollution during the consultation, however it would appear that Intertek have chosen to ignore them. Common theme. Anyway, Intertek response was,
“Air pollution was assessed to an appropriate level to address the Regulations. Air pollution modelling was not considered appropriate for the application”.
If this was the case, then we would consider the Regulations to be inadequate, however if you actually look at the regulations, they clearly say:
1) The environmental statement must contain—
(a) a description of any aspects of the environment likely to be significantly affected by the proposed cargo transfers, including—
- (i) humanbeings,faunaandflora;
- (ii) soil, water, air, climate and the landscape;
- (iii) material assets and the cultural heritage; and
- (iv) the interaction between any two or more of the things mentioned in sub-paragraphs (i) to (iii);
If the consultants consider that that air pollution was assessed to an appropriate level in the 2 pages that they produced then surely this must raise questions as to their understanding of the regulations? It doesn’t even talk about the effect of cargo transfers on air!
