2~1 -I SWS Natural Resources Ltd %r - MEMBER OF To: File Planning Reference No: 0417531 Planning Department Cork County Council Model Business Park Model Farm Rd Cork cc: Mr John Ronayne, Senior Plannner Mr Jim Hughes, Executive Planner ENVIR0NMENTAL PROTECTION AGEMCY WASTE LICENSING RECEIVED 15,NW 2004 INITIALS... . . . . . . = . . . . . . . . Date: 12’” November 2004 BCC: Mr John Deasy, Assistant County Manager, South Cork Mr Liam Ryan, Town Clerk, Youghal Town Council MS KarenVaughey, Environmental Protection Agency RE: Submissions Received by Cork County Council Planning Department To Whom It May Concern: Please find attached a comprehensive response to the issues raised in the nine submissions received by Cork County Council Planning Department in relation to the proposed AVR - Environmental Solutions Ltd. project, namely a Materials Recovery/Waste Transfer and Sludge Drying Facility in the townland of Foxhole near Youghal, Co. Cork. We would also like to confirm with Cork County Council due to the flooding recently experienced in the general area that the proposed site is not subject to flooding. As part of Environmental Impact Statement and Design works this was fully investigated. Finally, a Youghal Town Councilor requested a public meeting this week in the press. AVR - Environmental Solutions Ltd. proposes to hold an Information afternoon and evening in the last week of November. These information sessions will be advertised in the local newspapers. Any individual can come and ask questions on the proposed development. Project Manager I. ‘. . Shinagh House, Bandon, Co.Cork Tel: 023 41271 Facsimile: 023 41304 Email: forestryQsws.ie, Web: www.sws.ie Registered Off ice: Shinagh House, Bandon, Co.Cork. Company Reg. Nd. 137889. List of directors available at head office For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 25-07-2013:15:54:42
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2~1 -I SWS Natural Resources Ltd
%r -
MEMBER OF
To: File Planning Reference No: 0417531
Planning Department Cork County Council Model Business Park Model Farm Rd Cork
cc: Mr John Ronayne, Senior Plannner Mr Jim Hughes, Executive Planner
ENVIR0NMENTAL PROTECTION AGEMCY WASTE LICENSING
RECEIVED
1 5, NW 2004
INITIALS... . . . . . . = . . . . . . . .
Date: 12’” November 2004
BCC: Mr John Deasy, Assistant County Manager, South Cork Mr Liam Ryan, Town Clerk, Youghal Town Council MS KarenVaughey, Environmental Protection Agency
RE: Submissions Received by Cork County Council Planning Department
To Whom It May Concern:
Please find attached a comprehensive response to the issues raised in the nine submissions received
by Cork County Council Planning Department in relation to the proposed AVR - Environmental
Solutions Ltd. project, namely a Materials Recovery/Waste Transfer and Sludge Drying Facility in the
townland of Foxhole near Youghal, Co. Cork.
We would also like to confirm with Cork County Council due to the flooding recently experienced in the
general area that the proposed site is not subject to flooding. As part of Environmental Impact
Statement and Design works this was fully investigated.
Finally, a Youghal Town Councilor requested a public meeting this week in the press. AVR -
Environmental Solutions Ltd. proposes to hold an Information afternoon and evening in the last week
of November. These information sessions will be advertised in the local newspapers. Any individual
can come and ask questions on the proposed development.
MICHAEL & HELEN COPPERALLEY, 08/U/2004 08/11/2004 BROOKS
EOIN & MARGARET KINGSLEA, Ot3/11/2004 08/11/2004 CROWLEY
FRED & HERTA
GLENALLY HOUSE,
08/U/2004 08;Ii/2004 RIGNEY
DAVID & 4, HAZELMERE CAROLINE CLOSE. 08/11/2004 OS/ii/2004 O’BRiEN ,
JOHN RESIDENJSoF 08/11/2004 08/11/2004
;;i;z&E & COPPERALLEY &
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2 November 2004 7s3r
Re: Application made by AVR Environmental Solutions Ltd. under Planning Registar No. O-or Permission for a Waste RecoveryfTransfer and Sludge Drying Facility at Foxhoie, Youghai, Co. Cork
Dear Sir,
I refer to the planning application made on lst October 2004 for the above development and hereby submit the faHowii\g observation under Article 29 of the Planning and Development Regulations, 2001.
The site is located within an area zoned 1-04: industrial Estate Development for Smail and Medium Indusftial Units.
According td paragraph 9.3.36 of Volume 3 of the 2003 County Oevelopment Plan, “with certain exceptions as set out in the objectives below primarily’industriai areas are also generally suitable for waste management activities [including the treatment and recovery of waste material but not including landfill or incineration of waste genefated elsewhere)” [emphasis addedl.
These “certain exceptions” are spelt out in sub-objectives ZON 3-13 (b) and ZON 3-13 (c). It is quite clear from the wording of these objectives that the policy on the location of waste management in industrial areas is to direct general waste management’activities to areas which are zoned for Industry but will not be predominantly used for small to medium industry, warehousing or distribution.
The proposed use should be classed as a general waste management activity as it involves the drying of sludge in addition to the provision of waste recovery and waste transfer facilities. As the proposed site is zoned under I-04 specifically for small and medium industry, ZON 3- 13 (b) does not apply and the range of waste activity on the site is therefore restricted by ZCN 3-13 (c) to civic amenity sites and waste transfer stations. The proposed use of the site for sludge drying would therefore involve a material contravention of the Plan.
._ .*. ,.
Yours sincerely,
Padraig I&y - \ : 6 Elmside Carrigaline County Cork
Enclosure E20.00
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7 Copperalley Close, Youghal Co. Cork
5th November, 2004
The Planning Department, Cork County Council, Model Business Park, Model; Farm Road, Cork.
Dear Sir's,
RE/ APPLICATfON BY AVR-ENVIRONMENTAL SOLUTIONS LTD - FOR A PROPOSED WASTE RECOVERY/-S= SLuDGE.DRYINT FACILITY AT
FOXHOLE, YOUGNAL, CO. CORK
PLANNING REG REF. NO. 04/7531
We, Dermot Ledingham and Norma Ledingham of 7, Copperalley Close, Youghal wish to make an observation in relation to the abdve Planning Permission in connection with which we enclose a cheque for -&20.00 being the fee.
We live a substantial &sidentiai area,' which is just due west of the proposed recycling/sludge drying facility. ,We have, over the years experienced problems with the Youghal
L landfill, which currently takes waste from approximately a third of County Cork. While tbe.problems with the landfill now appear to be under control, it makes us aware how vulnerable we are to odours, dust and flies.
The area is zoned for industry, but it was always our understanding that this zoning was light industry and warehousing.
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We are concerned by the size, and especially the height .of the proposed building, which will dominate the sky line.
The Slob Bank is used by many residents at this end of the town for walking and has been a very important amenity for many years and the area surrounding it is now a candidate Special Area of Conservations, which we fully support.
While we are supportive of new jobs for Youghal in this instance we find it hard to understand why the waste from industries, which give economic benefit to other areas, should be send to Youghal for processing rather than being dealt with where it ,arises.
Our concerns are that the process of drying will inevitably result in obnoxious odours, particularly -in the light of the well publicised difficulties in many parts of the country that have arisen from the activities of the chemical industries, all of whom gave assurances ,at their Planning Application stage that, odours would not arise.
In addition, we are concerned that there will be noise, which, even tihen conditioned in a Planning Permission, will not be enforced. We are further concerned that there will be dust and ultimately, traffic twenty four hours a day.
We consider that the proposed industry is unsuitable for the site and not in accordance with the zoning and we therefore consider that the Planning Application should be refused.
'Yours faithfully, .
DERMOT LEDINGHAM NORMA LEDINGHAM
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Cumann na Daoine Women’s Group objection to planning application 04/7531 at Foxhole Youghal
Cumann na Daoine Women’s Group C/o Cumann na Daoine Youghal’s Community Development Project IO North Main Street Youghal Co. Cork 024 91900 [email protected]
. November 8th 2004
Objqtion to planning application 04/ 7531 Submitted to Cork County Council, November 8th 2004
AVR Environmental Solutions proposal for waste recovery/transfer and sludge drykg facility at Foxhole, Youghal
Cumann na Daoine Women’s Group has thirty members form all areas of Youghal. The group provides development and social opportunities and activities to improve the quality of life of the women of Youghal. The group is submitting this objection to the proposed waste treatment development at Foxhole Youghal out of concern for the quality of life of all-the community in Youghal. ;
The group’s objects to the proposed development on. the following grounds:
Itiadequate public consultation ‘Public consultation on this proposal was inadequate, almost non-,existent. Although three representatives of the community were consulted there was no public meeting, no plans were put on display locally and no detailed reports appeared in the local media. This lead to fears and concerns spreading through the town, making it difficult to discover the truth behind the proposal. We feel that the people of ‘l’oughal were entitled to a public information meeting, easy access to the plans and local media tovera~~ of the proposal. :
Emissiqns We are concerned about the potential impacts on our local environment. We believe there will be odour and fume emissions from the proposed waste treatment plant. As Youghal is a Heritage Town with a growing population and a dependency on tourism, any negative impacts may damage the residents’ quality of life and lead to a decline in tourism.
Amenity/recreation impact The proposed site is close to a bird watching area. Any impact on the site will affect the amenity/recreational value of the bird watching facility for local people. The bird watching area may or not be a protected area such as a Special Area of Conservation or a Special Heritage Area.
Traffic movement The proposal states that there will be 38 traffic movements a day, but this may be an underestimation of what will happen in the future. Because of the narrowness of the
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Cumann.na Daoine Women’s Group objection to.pl&ning zqplicatiok 04/7531 at Foxhole Youghal
streets in Youghal Town centre, the density of the population and the fact that there are schools en route in and out ofthe town, it would be impossible to accept that trucks containing odorous waste be routed through the town. All traffic movements would have to be via the bypass. This would be impossible to enforce. The proposed volume of traffic would quickly deteriorate the lane accessing the site and the approach road and roundabout. At present the surface of the lane is very poor and there isn’t enough space for two trucks to pass.
Proxi&t$ to businesses and dwellings There is a newly built business park adjacent to the proposed site. Some of the units in the business park remain vacant. If permission is granted to the proposed waste treatment plant, it will act as a disincentive to locate businesses in that part of Youghal. In the long term, the proposal may cost more jobs than it provides. There are dwellings very close to the site. Any increase in traffic volumes or emissions coming from the proposed plant will impact negatively on the quality of life of the residents.
Potential long terni impacts If the proposal is given permission, it may open up the possibility of a cluster of waste treatment facilities adjacent to the existing landfill. Youghal may become the waste management town of County Cork. This would be a disaster for the local community as it minimises the tourism potential of the heritage town and impacts negatively on the residents’ quality of life.
Questions of clarification relating to the proposal Sludge drying - What kind of sludge? How much of it? How can \Ge be sure that no toxic sludge or waste will be treated at the plant? Waste recovery facility - How will the waste be recovered? What kind of waste will be recovered? Waste quarantine area - What is a waste quarantine area? Dried sludge discharge area - What is meant by “discharge”?
Summary Cumann na Daoine Women’s Group, a community group in Youghal, object to the proposed waste recovery/transfer and sludge d*ng faci’fity et Faxh&, %~&a1 b&&&e:.
l Lack of public consultation : 9 Concerns about emissions
l Proximity of the proposed facility tb dwellings and businesses l Impact on tourism l Impact on quality of life for residents . Potential for a long term development of a cluster of waste management facilities 8 The need to clarify specific questions about the proposal
Signed:
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The Planning Dept, Cork County Council Model 33usiness Park Model Farm Rd. Cork.
Michael & Helen Brooks CopperalJey Youghd co co*
5* November 2004
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De& Sir/Madam
RE: APPLICATION BY AVR-ENVIRONMENTAL SOLUTIONS LTD. -FOR . A PROPOSED WASTE RECOVERY / TRAN!WER SLUDGE DRYING
FACILITY AT FOXHOLE, YOUGJiXAL, CO CORK.
PLANNING REG. REF. NO. WS31
We, Helen & Michael Brooks would like to make an observation and objection with regard to the above mentioned planning application, please find enclosed the cheque for e 20.00, as requested.
. Our main objection is with regard to the lack of inform&& and tack of consultation with the locai people which this type of facility could affect. There is a planning application notice on the fence of the proposed site, but as this is a cul de sac, the only people who will see this are those leaving the dump as the fence is at an angle to the road, is this legal ??
Yoighal is a heritage town which attracts many tourists every year because of $s history and water front, (the River Blackwater 11111s into the Atlantic Ocean through the town). The proposed site which is part of the Nob-lands is land reclaimed from the River Blackwater by the use of a bank ,made from stx+ a.32 day @xi& was built in 1845. Youghal Town Council have made the slob bank into an amenity area and have maintained and s&aced the bank and added seating for the many people who use this for walking, bird watch& and fishing etc. etc.
This proposed sludge drying facility which will manage 110,500 tonnes of waste annugfly, will be in full view of anyone who uses this n%reational area, and they will be affected by the odours and smoke emitted from, this facility. I understand that these facilities have to go somewhere, but our area already has a Super Dump which takes waste from a number of counties and Cork City, so enough is enough !! .
Dear Sir, We object to the above planning application on the following grounds:
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The planned location is on the banks of the Blackwater Estuary in a future amenity area. The existing council recycling and dumping facility located in Foxhole has a limited lifespan. We think that the future of this area should be amenity based in such a way that is likely to attract visitors to Youghal. Tourism is the most important industry in YoughaI at the moment and is likely to remain so for the foreseeable future. The proposed buildings and stack would be visual eyesore on the estuary skyline. The proposed development will introduce substantial HGV traffic into our community. The residential part of the town is expanding nerthwards towards this proposed site. A large residential block, including our dwelling, is currently located less than half a kilometre from the proposed site. The proposed . develoIjmiiktit ~i~s~~-~~ie’~~~~~~o~~~~ v-;;;;;;unity in this dire;tion.
, _. .
The anticipated Government decentralisation programme drew a small response to relocate to Youghal: A grassed amenity area on the banks of the estuary, rather than an industrial sludge dryer site, is far more likely to encourage people to resettle to the town. The proposed development is not in line with stated government policy of dealing with waste in the location that generates the waste. The proposed development is a private development. We don’t think that the profit reward for the speculation of a few outweighs the lessening of the quality of life of a community.
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The Planning Officer , Planning Dept.
Cork County Council Model Business Park Model Farm Rd. Bishopstown Cork.
We object to the above application on the following grounds. _
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5.
6.
7.
The proposed location is at the mouth of the Blackwater next to the Youghal UDC Dump v&i& has a limited lifespan and will become an amenity area in time. Current Development at Foxhole is Light Industrial / Commercial / Retail wheras this proposal appears to be Heavy Industrial involving HGVs delivering in excess of 100,000 tonnes of waste annually for processing.’ The proposal shows a 15metre chimney stack which would visually detract from the coastline. Foxhole is an established Bird Sanctuary and is currently the breeding stronghold of the Little Egret of which there are no more than 100 pairs in Ireland. There are a considerable number of dwellings in the immediate area some very close to the proposed site who would undoubtedly suffer Tom noise and odour pollution. Waste should surely be treated close to the area where it is generatednot in a ’ Town which having last all of its major industry is now ever more dependant on Tourism for its livelihood. The C3wmment dec. $~$r-gi&LJ~* p*gg4;fTm- p. . c’+z*%umarkcd .Youghd for 200 workers + far&es. This Development will do nothing to attract those people.
. .- . . .
Yours Sincerely
Fred Rigney Herta Ri5ey
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4, Hazelmere Close Tallow Street, Youghal, Co. Cork
5th November, 2004
The‘ Planning Department, Cork County Council, I Model Business Park, Model Farm Road, ,:- ._. . . . .I Cork. : '.
--.
,De+r Sirs,
. . RE/ APPLICATION BY AVR-ENVIRONMEW!AI, SOLUTIOk LTD - FORA PROPOSED WASTE REEOVE%Y/TRANSFER SLDDGE DRYING FACILITY AT
FOXHOLE, YOUGBAL , CO. CORE
PLANNING REG REF. NO. 04/7531
We, David O'Brien and Caroline O'.Br.ien. of 4, Hazelmere . . Close, Tallow Street, Youghal wish to make an observation
We live 'a substantial residential area, which is just due west of the proposed recycling/sludge drying facility. We have, over the years experienced problems with the Youghal landfill, which currently takes waste from approximately a third of County Cork. While the problems with the landfill now appear to be under control, it makes us aware how vulnerable we are to odours, dust and flies.
The area is zoned for industry, but it was always our understanding that this zoning was light industry and warehousing.
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We are concerned by the size, and especially the height of the proposed building, which will dominate the sky line.
The Slob Bank is used by many residents at this end of the town for walking and has been a very important amenity for many years and the area surrounding it is now a candidate Special Area of Consesvations, which we fully support.
While we are supportive of new jobs for Youghal in this instance we find it hard to understand why the waste from industries, which give economic benefit to other areas, should be send to Youghal for processing rather than being dealt with where' it arises.
Our concerns are that the process of drying will inevitably result in obnoxious odoussI particularly in the light of the well publicised difficulties in.many pasts of the country that have arisen from the activities of The chemical industries, all of whom gave assurances at their Planning Application stage that odours would not arise.
In addition, we are concerned that these will b& noise, which, even when conditioned in a Planning Permission, will not be enforced. We are further concerned that there will be dust and ultimately, traffic twenty four hours a day.
We consider that the proposed industry is unsuitable for the site and not in accordance with the zoning and we therefore consider that the Planning Application should be refused;
DAVID O'BRIEN CAROLINE O'BRIEN
3 . 1 cd Encl.
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-The Planning Department, Cork County Council, Model Business Park,
. . . , .., .~ ,- ModelFarm Road, _ . ,. CORK:
Copperalley Close, Copperalley,
YOUGHAL, Co. Cork.
5th November, 2004
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Dear Sirs,
RE: APPLICATION BY AVR-ENVIRONMENTAL SOLUTtONS LTD. - FOR A PROPOSED WASTE RECOVERY/TRANSFER SLUDGE DRYING FACILITY AT FOXHOLE, YOUGHAL,
CO. CORK
PLANNING REG. REF. NO. 04/7531
. ..’
I, John O’Keeffe, of Copperalley Close, Copperalley, Youghal, together with the undersigned residents of Copperalley and Greencloyne, Youghal, wish to make an observation in relation to the above Planning Application, in connection with which we enclose a cheque for f20.00, being the fee.
We live in a’ substantial residential area, which is just due west of the proposed recycling/sludge drying facility. We have, over the years experienced problems with the Youghal landfill, which currently takes the waste from approximately a third of County Cork: While the problems with the landfill now appear to be under control, it makes us aware how vulnerable we are to odours, dust and flies.
The area is zoned for industry, but it was always our understanding that this zoning was for light industry and warehousing.
We are concerned by the size, and especially the height of the proposed building, which will dominate the sky line. i
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The Slob Bank is used by many residents at this end of the town for walking and has been a very important amenity for many years and the area surrounding it is now a candidate Special Area of Conservation, which we fully support.
While we are supportive of new jobs for Youghal in this instance we find it hard to understand why the waste from industries, which give economic benefit to other areas, should be sent to Youghal for processing rather than being dealt with where it arises.
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Our concerns are that the process of drying will inevitably result in obnoxious odours, particularly in the light of the well publicised difficulties in many parts of the country that have arisen from the activities of the chemical industries, all ‘of whom gave assurances at their Planning Application stage that odours would not arise.
In addition, we are concerned that there will be noise, which, even when conditioned in a Planning Permission, will not be enforced. We are further concerned tn,at there will be dust and, ultimately, traffic twenty four hours a day.
We consider that the proposed industry is unsuitable for ‘the site and not in accordance with the zoning and we, therefore, consider that the Planning Application should be refused.
Yours faithfully,
John O’Keeffe and others whose signatures and addresses are attached to this letter.
Enclosure - Cheque for G!O.oo ‘:-..‘.. ” .. i 1: .” ̂ “.
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RE: APPLICATION BY AVR-ENVIRONMENTAL SOLUTIONS LTD. -FOR A PROPOSED WASTE RECOVERY/TRANSFER SLUDGE DRYING FACILITY AT FOXHOLE, YOUGHAL, CO. CORK
PLANNING REG. REF. NO. 04/7531
,
We have read the letter d,ated Sh November, 2004, and signed on our behalf by John O’Keeffe of Copperalley Close, Youghal and, sign herein our consent to
RE: APPLICATiON BY AVR-ENVIRONMENTAL SOLUTIONS LTD. - FOR A PROPOSED WASTE RECOVERY/TRANSFER SLUDGE DRYING FACIFITY AT FOXHOLE, YOUGHAL, CO. CORK
PLANNING REG. REF. NO. 04/7531
,
. .
We have read the letter dated Sh November, 2004, and signed on our behalf by John O’Keeffe of Copperalley Close, Youghal and sign herein our consent to
Thank you for yoti l&t&of I@’ &igust 2004 and enclosed public consuItation leaflet in relation to the proposed Materials Kecovery and Sludge Drying Facility in the tow&and of Foxhold mar Yoq&.l, Co. C&.
As the proposed developkinent is rtot Located on a national road, it is therefore outside the retit of the Authority.
t 1.
Email: infoQnra.ie Web: www.nra.ie
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Mr. Tom Burke Coastal Zone Management Division Department of Communications, Marine and Natural Resources Oak House Bessboro Mahon Cork
20thAugust 2004
Dear Mr. Burke
Thank you for your response regarding our consultation information on behalf of AVR -
Environmental Solutions Ltd. for a proposed Materials Recovery and Sludge Drying Facility in the
townland of Foxhole near Youghal, Co. Cork.
Following your recommendations, copies of the consultation material have also been forwarded
to Mr. Seamus Gallagher, Sea Fisheries Control Officer, and Mr. John 0’ Keeffe, Regional
Engineering Office, both of your department.
Your information regarding a Foreshore Licence application is greatly appreciated. We are
presently investigating this process. Thank you also for your direction concerning the shellfish
operations. We are currently assessing any impact our proposed development may have on the
receiving waters and we shall meet all National and EU criteria concerning emission limits.
If you have any further concerns or opinions you wish to express regarding this development,
please forward them in writing to the undersigned.
Yours sincerely,
Declan Waugh B.Sc. MIEMA. MCIWEM. MIOA. MSEE
Senior Environmental Consultant
SWS Environmental Services
SWS Group
Shinagh House
Bandon
Co. Cork.
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EPA Export 25-07-2013:15:54:45
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-77 TAISCE - THE NATIONAL TRUST FOR IRELAND
Is’ September 2004
Declan Waugh SWS Environmental Services Shinagh House Bandon co corlc
‘Dear Mr Waugh
REF: Environmental Impact Statement for materials recovery and sludge drying facility at Youghai, Co Cork
Your letter of 11” August, 2004, raises concerns and creates undesirable confusion between the preparation of an Environmental Impact Statement which is done by consultants on behalf of an applicant, and the carrying out of an Assessment which is done by the decision making authority.
.Accordingly, we would advise. that the content of your letter of 11” August, 2004, which has been circulated to ourselves and other consultees should be withdrawn and it should be clearly stated that what SWS Environmental Services is preparing is an Environmental Impact Statement on behalf of the client.
We would appreciate if.you couldzonfirm when this action will be taken. When you re-issue a proper consultation letter, we will then coniment on this EIS scoping.
.: Re: Proposed Materiali Recovery and Siudge Drying Facility at Youghal
1 Your letter of I Sth,+qgd addressed to t&z tZThimm of Aer Rimta refers. We have no comments oii this ,piiiposd.
. _ ,,. ,, .:; . . i (, _,. ‘1 . .
Boa&i of Directurs
Newt ifanion - Chahman, Pat Fitzgerald, Peter Dunne, Liam J. h&de, Freda Hayes, Cecil Brett Joseph Gantly, pattick M. Shanahan, Margaret Sweeney - Chief Executive