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HomeMy WebLinkAbout2660018 - Submission - Blackesh Biogas Plant Concern Groupe / 7 FE 9 2026 Ocr- a 3 cam4i, Blackesh Biogas Plant Concern Group. C/O Darren Connolly Drumanny, Drum, Co. Monaghan. 16th Febuary 2026. Planning Department Monaghan County Council 1 Dublin Street Monaghan H18 X982. Re: Planning Reference: 2660018. Applicant: Stream BioEnergy Ireland Limited. Development address: Maghernakelly, Drumcall and Drumgole, Drum, Co. Monaghan. Development description: Renewable Biogas Plant. Dear Sir / Madam, We herewith lodge our objection to the above development. We recognise the demand for renewable energy and have perused the application, and we respect and accept the requirement for renewable energy in Ireland. However, the applicant has selected a site on a Drumlin foothill (as defined at Figure 6.1 of Monaghan County Development Plan 2025-2031- Landscape Character Types- Drumlin Foothills), where massive earth moving (18,600 m3) is proposed that will irreversibly scar this Drumlin landscape, and to construct massive industrial structures that are out of scale with adjoining properties and land uses, and are alien to the character of the rural area. We note from the application that other sites were considered, however, no sites were considered in proximity to the current and future end user of the bulk digestate produced by the proposed development, which are the tillage areas of the country per the Teagasc map hereunder, with predominately low-lying topography, or possibly existing brownfield sites that should be much more viable to the applicant. These areas already have extensive gas pipeline infrastructure as outlined on the 2"d map (Gas Networks Ireland — Pipeline Map) hereunder. Our objection is based on the objectives as set out in the Monaghan County Development Plan 2025-2031, and the Irish Bioenergy Association recommendations as follows: Extract from Monaghan County Development Plan 2025-2031 1.0 Introduction. The Monaghan County Development Plan 2025-2031 provides an overall strategy for the proper planning and sustainable development of County Monaghan over the timescale of the Plan. Spatial planning through the development plan objectives and policies endeavour to achieve balance between the common good and the interests of individuals. It is acknowledged that many of the major issues affecting development in the County are determined by national policy and government funding. The reform of local government in 2014 focussed on what could be achieved locally by working together to bring about a higher quality of life and more sustainable economic development in County Monaghan. Following extensive research and consultation to identify the key challenges, opportunities and priorities from both a community and economic perspective, Monaghan County Council working alongside Monaghan Local Community Development Committee (LCDC) published the first Local Economic and Community Plan (LECP) for County Monaghan covering the period 2015 to 2021. The proposed development on an industrial scale that completely alters the natural landscape and replaces it with massive structures that are out of scale and are alien to the character of the rural area, and are grossly inappropriate at the proposed site. This is contrary to the above highlighted strategy, objectives and policies. Extract from applicants planning statement: 4.4.7 Monaghan County Development Plan 2025 -2031 Locally, NWMPCE 2024-2030, which provide specific guidance on the siting of biological treatment facilities. The site satisfies all relevant criteria, including sufficient buffer distances to avoid nuisance effects such as dust, odour, and noise; proximity to feedstock and end -use destinations; suitability within a rural agricultural landscape; close connection to the gas network for direct biomethane injection; visual screening and appropriately designed odour- emission stack; separation from surrounding farmland; and access to the national road network. These criteria confirm that the proposed development site is fully consistent with national and local waste and renewable energy policy, delivering a renewable biogas facility that effectively balances operational, environmental, and community considerations while supporting Monaghan's circular bioeconomy. and the The above highlighted statement is inaccurate and the proposal clearly contravenes objectives of the said County Development plan as follow: Extract from Monaghan County Development Plan 2025-2031 15.12.2 Industrial and Commercial Developments Outside Settlements It is accepted that there may be circumstances where it is not possible or appropriate to locate a commercial or industrial development within a settlement. This may be due to matters such as a lack of suitable lands or infrastructure, the need to locate beside an existing development to benefit from synergies, or the need to locate beside a fixed resource. In these circumstances, industrial and commercial developments may be considered acceptable where it can be justified to the satisfaction of the Planning Authority in accordance with the criteria detailed below. Generally, sites adjacent to settlement envelopes shall be given preference over those located in the wider rural area. Proposals for industrial/commercial development or the expansion of an existing business outside settlements, shall generally comply with the following: a) It is demonstrated that there is no alternative suitable site within the boundaries of nearby settlements and the proposed development is appropriate at the proposed location. Other sites were considered per the applicant; however, no sites were considered in proximity to, or on route to the current and future end user of the bulk of the digestate generated by the proposed development process. The end users are the tillage counties of the country per the Teagasc map hereunder. In addition, we consider an industrial scale development that completely alters the natural landscape and replaces it with massive structures that are out of scale and are alien to the character of the rural area, and are inappropriate at the proposed site. This contravenes the said objective. b) Where relevant, it is demonstrated that the proposed development is tied to a fixed resource and/or requires an extensive site area or specific settings. The proposed development uses specific feedstock but is not tied to the locations where the feedstock is generated, and does not require a specific setting, other than within reasonable distance of a gas pipeline network. c) The design, nature and scale of the development integrates with the surrounding landscape and will not detract from the character of the rural area. The proposed development is for massive earth moving / scarring of the landscape, and with structures of industrial scale as depicted in Photo montage — viewpoint 4 and 9 of the application, that will detrimentally injure and detract from the character of the rural area. We note that the said montages and the other montages were generated while nature was in full foliage, and there are no montages from close quarters e.g. the Blackesh cross. All of the mature hedgerows depicted bounding the proposed site have since been substantially cut back. In addition, the fact that the application includes for the very extensive earth moving, planting, landscaping, creating earth beams etc, only proves that the proposal is too massive to be appropriate on this site, and certainly does not integrate with the surrounding landscape, and will surely detract from the character of the rural area. d) There is no significant adverse impact on the amenity of occupants of nearby properties as a result of the proposed development such as noise, light and/or odours. Occupants of some nearby properties moved to and renovated existing dwellings some years ago to escape industrialised areas, while other occupants built dwellings in the area, all for the clean air and rural landscape views and setting. The proposed development proposes to eradicate a natural drumlin foothill and replace it with massive structures that are out of scale and alien to the amenity values of the natural landscape. Raw poultry manure can have a distinctive unpleasant ammonia odour, particularly when off-loading HGV's and although the proposed process has systems to minimise odours there is no guarantee that there will not be odours from the plant. Members of this group visited Tully bio-gas plant (Stream BioEnergy) at Ballymena NI, separately to the applicants organised visit, and had conversation with a few of the local inhabitants. It was confirmed that there is an 'odour control monitor' person employed to regularly check for odour along the site periphery, and in the event of odour being detected, instructs the plant to adjust the process to reduce odours. This confirms that there can at times be unpleasant odour being emitted. It was also observed that Tully Bio-gas plant is situated within a larger quarry site and is not directly adjacent to a primary public road. There are existing residences to the North and Northeast, that are located on elevated sites, and are in approximate alignment with the top of proposed 20m high dispersion stack. These residences may be affected by the elements that are within the discharge from that stack. e) The traffic generated by the proposal is appropriate for the surrounding road network, will not result in unsustainable traffic movements and will not necessitate roads improvements that would damage the character of the rural roads in the area. The cross-roads junction roadside verges contain Drumgole group water scheme underground infrastructure. All members of this group are customers of the said group water scheme and have concerns regarding damage to this infrastructure particularly during earth moving operations. The application includes for transporting thousands of tons of spoil via the cross-roads, which is significantly elevated above the adjoining field levels. This operation will most likely be by means of large dump trucks which will generate considerable vibration through the road structure which may cause fracturing of the road structure or group water scheme infrastructure. The group who visited Tully bio-gas plant observed five HGV's entering and five HGV's exiting the site, within a timeframe of forty-five minutes, suggesting that the volume of traffic will be significantly more than advised. f) A high -quality layout scheme is proposed which demonstrates that the site is not dominated by extensive car parking, hard standing or roads, and that the topography and surrounding landscape are respected as appropriate. The development proposes to completely alter the existing topography of the site with massive earth moving, form unnatural earthen mounds for screening, and to obliterate the visual landscape and replace with massive industrial structures that are alien and disrespect the rural area. 15.17 Renewable Energy Development The Planning Authority will support, encourage and facilitate renewable energy proposals at suitable locations where it is demonstrated that the development will not have a detrimental impact on the visual and residential amenities of the surrounding area and other matters of acknowledged importance. Proposals for wind energy development must meet the requirements as set out in the Wind Energy Development Guidelines (DEHLG, 2006). The Planning Authority will have regard to the DHLGH's Draft Wind Energy Guidelines (2019), and any new or updated/subsequent versions, when considering planning applications for wind energy developments and modifications to existing developments. Other forms of renewable energy include anaerobic digestors, battery storage, biomass/bioenergy, solar, geothermal and hydro power/storage. At present, there are no national planning guidelines for these types of energy developments. Therefore, the Council shall assess individual applications having regard to normal planning considerations and the locational criteria applicable to other types of renewable energy developments. Proposals for renewable energy development, including associated infrastructure and connection to the grid, shall not have any adverse impacts upon: a) The visual amenities of the area and surrounding landscape, either individually, or cumulatively with other similar projects in the area, particularly in respect of the scale size and layout of the project and the degree of visibility over extensive areas. The scale size as depicted in Photo montages —viewpoints 4 and 9 of the application depicts massive industrial structures that are alien to the rural area, which will have adverse visual impact, over significant distance from all approach roads. This is contrary to the above. The lands to the north and northwest of the proposed site are in private ownership. Both land parcels (north of L2280 and L2320) have potential for development of single rural dwellings. Should permission be granted for the development, both these land parcels will lose the potential for the said development and therefore the value of those lands is drastically reduced. IRISH BIOENERGY ASSOCIATION. Extract from: PLANNING GUIDANCE RECOMMENDATIONS FOR BIOENERGY PROJECTS IN IRELAND Pages 74 and 75 4. It is vital that county development plans set out clear development policies which designate areas where bioenergy development is designated as either 'open to consideration' or 'not permitted'. Examples of sites which may be 'open to consideration' for large scale projects (1 MW+ thermal) are outlined below; • Rural Brownfield sites (e.g. former creameries) • Urban Brownfield sites (e.g. vacant industrial lands) PLANNING GUIDANCE RECOMMENDATIONS FOR BIOENERGY PROJECTS IN IRELAND • End -Market Use • Road Access • Proximity to sites suitable for the disposal/use of by products The Irish Bioenergy Association recommendations (extracts above), recommend Rural Brownfield or Urban Brownfield sites for such developments. The site selected is anything but a brownfield site, and not in proximity to the end users of the byproducts. This document was presented to the applicants' representatives at the public meeting in Rockcorry School on Tuesday 9th December 2025, where the said representatives confirmed that the document was considered at site selection stage. We also submit the following observation: We refer to the recorded monument MOO22-008 'Hilltop Enclosure' that is situated West (depicted below) of the proposed site, and owned by the same land owner. MO022-008---- : Hilltop enclosure: MAGHERNAKELLY Description: Situated on top of a drumlin. k' it is depicted as a large oval embanked enclosure on the 1834 edition of the OS 6 -inch map where it is described in gothic lettering as a 'fort', and as a large ♦ hachured oval feature on the 1907 MAGHEr edition. This is an oval grass -covered area (dims 107m NW -SE: 69m NE -SW) defined by a scarp (Wth 1.2-1,3m; H 1.7-1.9m) and hedge, with a field bank at its base N -SSE replaced by a farm track SSE -WNW, An original entrance is not identified. The above description is derived from the oom to ••• Below is an extract from Google Maps showing the recorded monument MOO22-008 'Hilltop Enclosure' with mature hedgerow extending North and turning East North-East. It also shows wetland to the low-lying section of the field adjacent to the L2280 and L228O2 public roads. Extract from latest satellite imagery (2025) shows the mature hedgerow removed up to the recorded monument MO022-008 'Hilltop Enclosure', and three land -drains in close proximity to the recorded monument MO022-008 'Hilltop Enclosure'. It also shows covering -up of the wetland, which would have been wildlife habitat for nesting birds and in particular smooth Newts. I These works were carried out during the summer period 2025, and in our opinion were carried out in an effort to mitigate possible visual, Archaeological and environmental impacts of the proposed development. At this time, we do not know if the required permits were sought or granted for works in close proximity to the recorded monument MO022-008 'Hilltop Enclosure'. Closing statement It is the opinion of this group, that the proposed development on this site, is incongruous and incompatible with the Drumlin landscape, and it clearly contravenes the objectives of Monaghan County Development plan 2025-2031 as noted above. It does not align with Proper Planning of the area or achieve balance between the common good. It also contravenes the recommendations of the Irish Bioenergy Association 'Sites that may be open to consideration' as described above. In addition, it absolutely 'beggars' belief' that the objectives of the said development plan and IRBEA recommendations, were not adequately considered at the site selection / pre -planning stage, and more particularly at pre -planning consultations. There are a multitude of much more suitable sites along the transport route to the end users of the digestate, where the topography is low-lying and therefore removing the necessity for massive earth moving and destruction of a drumlin foothill, and where adequate set -back distance from the public view is achievable. A suggested possible much more appropriate local site is located beside an existing poultry growing unit at Corravan, Newbliss, per planning Ref: 18160. A development of six poultry houses that are very significantly set back from the public road, where visual impact would be massively reduced and with little or no excavations required. There are also seven large, masted wind turbines in this general area. We respectfully request that permission forthe development at this site be refused. Soil suitability for tillage in Ireland Source: Teagasc Highly suitable 1 Suitable Moderately suitable Marginally suitable Mainly unsuitable Water Urban Pipeline Map \PL11^.� I:� i•r •tea.= -.s �A .L _f - i!eae ,. Ksa- fir. 1' 0 r-yrf1''Lnaf P kY.v J `J c �. I Blackesh Biogas Plant Concern Group Objectors: Name: Address: Eircode: Tel. No.: Signature: Patrick Clerkin Drumhay Newbliss. 41 Anthoney Lynch Tomaney Rockcorry ' / � �, 83 Sarah Jane Breen Drumgole Rockcorry r� ' 84 Michael J Brady Aghadrumkeen Rockcorry � Blackesh Biogas Plant Concern Group Objectors: Name Address Si nat a No. C\v r\Oc < Oro eic O 15 ai\oc\ prc -t ,tfc-L \OO 2.t -r .e U r'e' It ft J i16(J12rt11 /c •c i N Cj ( O 2. k .4,scg" cl40.-�q d O-' f1�.✓'/ �- �/ ll 1 dYt.rfL" -Ai' ✓i •t . +v. \ 0 EdQ J O Ce O O Scrk 9fl,1, I r i O 6 C� v� G j i 0 I2 S �< u- t, n C r1v'\ I ,11 \ O 4 %t G O �fwc"-t-Q- U tt 1 � -N,s ' 't r?fJ 1 MC(!O I(7uc t t LQL&c,e ��s����t �— E C9,J..k to It z Q LjceJ_ qj c1c CcJ'1c4L A-VQJJ 1LS__ C 'G��• lL, a 7 �(01i1 r oC-1 , ,� Tr -; ______