B) Ecology issues

***Use your OWN words – do not copy ours – or your planning objection may not count***

1. Dorset Council has declared a Climate and Ecological As have Portland Town Council and Weymouth Town Council. Emissions of nitrogen oxides from waste incinerators are typically close (about 85 – 90%) to maximum permitted levels.  Increased nitrogen deposition on nearby protected areas of international and national importance, including the calcareous grasslands of Portland particularly sensitive to nitrogen deposition, is a real threat to the biodiversity of these areas regardless of any data the planning documentation has provided.  ‘In combination’ levels of Nox deposition likely to breech critical thresholds for Chesil Beach and the Fleet SPA. This conflicts with the DC Climate and Ecological Emergency Strategy and draft Action Plan– the draft gives as an aim: “Dorset becomes the clean air place to live and visit”. https://news.dorsetcouncil.gov.uk/2020/09/28/dorset-council-publishes-climate-and-ecological-emergency-action-plan-ahead-of-cabinet-meeting/  Ammonia in emissions is likely to breech critical thresholds for harm to the Special Area of Conservation (SAC), a European site.  This area is extremely rich in rare lichens and briophytes (mosses).  They and the whole ecosystem around them are very sensitive to ‘nutrient enrichment’ from nitrogen deposition.  A large area of the SAC would be impacted but PfP appear to dismiss this as an acceptable level of harm.  By law, they should take a ‘precautionary approach’ to a sensitive habitat and PfP have not done so.  Portland currently has comparatively clean air enabling rare species to survive and even thrive.  The additional ammonia and nitrogen pollutants would drive the SAC towards exceeding critical levels.  The PfP survey on bats is superficial and lacks supporting evidence.  PfP have not proven NO adverse impacts on SAC/SPA. (see B2)
2. Counter to Waste Plan 2019 statement that proposals will not be approved unless the Waste Planning Authority is satisfied that there will be no adverse effects upon the integrity of European and internationally protected sites, in accordance with Policy 18 (WP 2019 9.31, Policy 6f; NPPF 174, 175, 176, Portland Neighbourhood Plan Port/EN0, Port/EN2, Port/BE6)
3. Source of RDF unknown, so content of RDF unknown and therefore levels and content of pollution unknown, therefore unacceptable risk to local ecology and biodiversity; precautionary principle should therefore be applied: LP ENV9; https://ec.europa.eu/environment/integration/research/newsalert/pdf/precautionary_principle_decision_making_under_uncertainty_FB18_en.pdf
4. Potential harm from pollutants to important, rare and unique ecology in a range of international (SAC), national (SSSI)and local (SNCI) designated sites on Portland
5. Potential harm to ecology of Chesil Beach and the Fleet Special Protection Area
6. Potential harm to ecology of Portland Harbour, a Sensitive Marine Area, and to nearby Marine Conservation Zones