RE: SAE9 Oct 2020 00:32
Question 2. Please provide written assessment of the ability of the proposed facility to meet the requirements of the Waste Incineration BAT Conclusions for new plant, including BAT-AEELs for energy and BAT-AELs for emissions. Your revised assessment shall fully consider not only the BATAELs, but also the techniques described.
SUP Response : We are prepared to engage constructively with you to identify options for obtaining a permit for the plant on the basis of its classification as a “New Plant” rather than, as we contend, an “Existing Plant”. However, this engagement is strictly under reservation of our right to rely on that contention in future. SUP can confirm the intent to assess the ability of the proposed facility to meet the requirements of the Waste Incineration BAT Conclusions for new plant, including BAT-AEELs for energy and BAT-AELs for emissions. Whilst we confirm the intent , we reserve the position to request derogation related to chemical species that are challenging to meet New WIBref ELV’s.