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Thanks Phyl, that's great to hear. In all communications they seem very very confident of getting all the right approvals - permit, planning permission etc.
I'm going to keep some cash back in case we haven't had news by December and the stock markets start falling for Brexit. I'd love to be able to buy a few more shares for under 20p
I completely overlooked the part where they said they could meet the new standards. Thanks OHS!
In which case I can't see any barriers to getting the permit. The only other consistent quibbles NRS have had have been over water discharge, but that just seems to be some kind of number/unit error rather than an actual eutrophication concern. Feeling very confident now.
The planning application runs parallel to the permit application right? We could end up with planning permission before we get the permit approval?
And thanks for all your contributions to the board OT! Always enjoy reading what you have to say
OT: yes, that's a good point about the Mitsubishi tests. I think TC said that SAE could update some of the probabilities of being able to hit targets (from low to high?) after those tests.
When I take a step back from all the detail (which mostly goes over my head anyway!) I think it comes back to: would SAE have persisted with the application and spent so many months and so much time and energy on it if they didn't think they could get the permit as a new plant? I think the answer has to be no. TC sounds confident in all the interviews I've seen, and I would have thought that they'd have struggled to get financing without being confident of getting the permit.
Time will tell I guess. If the permit takes an extra few months but it does come through, I will be happy.
OHS: my motivation was that I was hoping someone might be able to reassure me either that SAE could easily make the design changes to achieve the new (rather than existing) emissions standards, or that derogation would be likely if not. I've been holding this stock (and watching this forum) for a while. I've never said anything before because I've never felt like I had a whole lot to ask or contribute.
For what it's worth, I hold a reasonable number of shares in SAE and am hoping to buy more when I am more confident about the state of the environmental permit. Although I'm pretty good with numbers and detail, I have zero knowledge of engineering or law - hence the research and the questions in my post. I wasn't trying to spook anyone into (or out of?) buying/selling!
OHS- haha thanks! Your posts are always informative and I've been very impressed with (and helped by) some of the info you've dug up.
Yes, I agree about the time that has gone into the project. SAE have known about NRW's plans to treat the plant as "new" for several months, yet still seem just as keen to continue the application. I can't see why they would still be pouring all this time, energy and money into it if they weren't sure that they could get it one way or another! I noticed that in the Lynemouth example you shared here, I think they were awarded derogation for that project?
Hi all, and thanks for the really helpful and well-researched discussions.
I'm a little unsure about the permit and am wondering if any of you can help me out.
From reading the correspondence between NRW and SAE it seems like the main reason that NRW "contend that different BAT-AEL apply to the facility than you [SAE] anticipated" ( see 02/10/20 message requesting more time) is because NRW want to treat the permit application as a new permit and a not a variation to the existing one. You can see this from the message sent Tue 11/02/2020 from David Poole titled "RE: NRW Request for Information - SUP comments". He says towards the bottom that "NRW's expected position is to regard your proposal as a new plant for the (co)incineration of waste, albeit utilising existing infrastructure". In a later email he confirms that this is their position since a permit to burn waste is defined as new (by the EU) if there is no pre-existing permit to burn waste. For Uskmouth, there isn't one since the previous permit was to burn coal.
Now if you look at the original Air Quality Assessment that SAE commissioned (03/12/2019) , in Table 3.2 they list the levels of emissions that they expect for various pollutants. Under EU and UK law (the industrial emissions directive, or IED) these have to be as good as the Best Available Technology - Associated Emissions Levels (BAT-AEL). You can see these levels yourself on tables 5 and 6 (pages 78 and 79) of the BATc document for waste incineration here:
https://eur-lex.europa.eu/legal-content/GA/TXT/?uri=CELEX:32019D2010
The important point is this: the BATc for WI document has different standards for new and existing power plants, where they are less permissive of emissions from new power plants. Since SAE were applying for a variation permit they were hoping to be classified as an existing plant, and if you look at Table 3.2 of the Air Quality Assessment and compare with Tables 5 and 6 of the BATc WI document, you can see that they do expect to meet the standards for existing plants. Unfortunately, they don't meet the standards for new plants for HCL, SO2 and NOx emissions.
As far as I can tell, they have 3 options:
1. convince NRW that they qualify as an existing plant and only need a variation permit.
2. make design changes to the power plant so that they meet the BAT-AELs for a new plant.
3. apply for derogation.
From reading all of the correspondence between NRW and SAE, I'm pretty sure that NRW have made their minds up about Uskmouth being a new plant for legal/permit purposes, so 1 doesn't seem to be an option. But I have no idea whether 2 or 3 are plausible options for SAE. Does anyone with engineering or legal knowledge know how cheap/easy it would be for SAE to improve the design of the power plant to meet new specifications, or how likely it is that they would be granted derogation?
Thanks!