Loading...
HomeMy WebLinkAbout2660018 - Submission - J Kenneth CrowePlanning 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, I wish to lodge to my objection to this proposed development. 2- J Kenneth Crowe Drumcall, Drum, Co' Monaghan 3 223 I have studied the proposed development details & plans & have physically inspected the area. Along with a considerable amount of time researching the purpose, use & impacts of such installations in Ireland, UK and across Europe. Although it is to be applauded that some forward -thinking engineering is being developed and implemented. It is important that planning departments maintain responsible control of the siting of such developments. Planning departments must not allow themselves to be swept up in some pioneering attitude that disregards both the natural environment and the living conditions of residents in close proximity. This proposed development is on a greenfield site with no prior industrial development (unlike other A D installations I researched in Ireland, UK & Europe). IrBEA Bio energy planning recommendations state that; 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) It also states; It is recommended that the following matters be considered as 'exclusionary factors' which may preclude the successful acquisition of planning permission for a bioenergy project. Consequently, these areas may be illustrative or areas where bioenergy development is 'not permitted'. Typical 'exclusionary factors' include proximity to: 0 Proposed Natural Heritage Areas or Special Areas of Conservation Airport Exclusionary Areas II Areas of High Amenity or Archaeological Interest 0 Appropriate zoning based on the County Development Plans Having identified areas which are not suitable to locate a facility, a more detailed assessment can be carried out having regard to the following criteria: 0 General Planning and Environmental Considerations 0 Site Size and Current Land Use IProximity to Residential Areas This proposed development is, irrespective of the "creative measuring" 99 Metres from a historic ring fort & close to the route of the Black Pig Dyke / Worms Dyke. Within close proximity to numerous private dwellings. Some of these private dwellings are in an elevated position. The foul air chimney stack on the proposed development is 40m high this releases its emissions at the same height as the kitchens, dining tables, barbeques & washing lines of those surrounding properties ours included. The very short period between informing SOME local residents and submitting the planning application is a clear indication that this is an attempt to push through an ill-advised poorly located installation, prior to any sensible and well researched policies being implemented. The decision to site the plant is based purely on financial gain on behalf of the landowner and to take advantage of European opinions on the need for A D facilities. Being submitted without any consideration for the life changing implications of local residents. The rural location of the proposed site deems the electrical supply to the site unfit, hence two 2MW generators will have to run permanently to power the site. Although attempts will be made to "soundproof" in the real world they will not only generate electricity but noise and emissions. The information forwarded by Stream Bioenergy states there will be "NO SMELL" A local concern group conducted our own visit to the site ran by Stream Bioenergy in Ballymena and carried out extensive collecting of information from local residents. There ARE foul emission from the plant which is less than half the size and capacity of the proposed site here. So much so that Stream employs an agent to drive around the area reporting back to the plant whereby they try and alter operational settings to reduce the emissions, or dare I suggest to temporarily divert to a different set of unfortunate residents. Modern construction rules for private dwellings dictate that roofing is vented, that roofing membranes are breathable and that sealed unit window encasements are vented. This in turn make it impossible for the foul air emitted from the facilities to be excluded from homes. I myself visited the Ballymena plant 25/02/2026. It was a damp cool day, approaching the area from a northerly direction with the vehicle navigation reading 2 miles to destination a foul smell permeated the vehicle via the heater vents and remained present until leaving the site. The Ballymena plant is not visible from the public highway at any point. A feature not shared by this proposed application. The service roads at the Ballymena plant could easily accommodate 30 plus HGV vehicles if any backlog occurred, and obviously in the event of an issue there is plenty of space to accommodate fire service or emergency service vehicles. The proposed site does not lend itself to these needs. I read with interest the submissions of support from a Poultry producer and local agricultural contractor. Naturally if a business generates over 70,000 tonnes of waste per annum and could utilise the proposed plant then their support is a foregone conclusion. I'm quite sure that the aforementioned producer eats their evening meal over 30km from the proposed plant. I appreciate the submission from the agricultural contractor as his experience and knowledge of local business needs holds far more substance. It should be made VERY CLEAR that at no point is the proposed site recommended as being a good choice of location by this experienced Agri contractor. He is very prudent with his wording as not to mention location or suitability, well done sir. Perhaps Stream bio-energy should enlist his services and experience to find a suitable site. It's noted that AnTaisce have a scheme commissioned by Monaghan council for a vision plan for Drum, this seems in complete opposition to the proposed development. The visual impact of development will have negative effect on tourism in the area visiting local lakes & enjoying the scenery. EIAR-VOLIINTS page 34 states there are no childcare/educational centres within 2.5km This is incorrect Drumcorrin national school is 2.4km from proposed plant. The proposed location is on the direct route to Drumcorrin national school. The crossroad location makes the plant visible from all 4 directions and is too close to the R189 to allow for safe movement of 40 tonne vehicles arriving and leaving the site 12 hours a day. The R189 is not of a condition to safely accommodate this extra traffic. The proposal states that there will only be 2 trucks per hour emptying at the site. That's 4 movements, per hour. However, upon our own aforementioned research there were 5 trucks entering the Ballymena plant in a 45 -minute monitored period that's 6.6 trucks per hour or over 13 movements per hour. Even using this research as an example from a site with less than half the operating capacity of the proposed site that would be an extra 6,240 Tonnes per day on our local roads. The proposal states that hauliers will be encouraged to only use designated routes to the plant. THAT STATEMENT IS LUDICROUS. Drivers will take whichever route they deem easier / quicker or just personally preferable, making the L2320 & L2280 dangerous, overloaded & damaged due their size & weight. When this was raised with Stream Bioenergy Chief Operating Officer I received a nonchalant shrug of the shoulders and his reply "we'll pay our rates so it's Monaghan councils problem" Information supplied suggests that individual farmers will be able to transport their farm waste to the plant which I have no doubt they'll take the shortest route. Drum village would become a major arterial route for heavy haulage carrying effluent & destroy a picturesque historic village. Drum village would also have to endure the safety issues at the Little Drummers pre-school centre, & Drumcorrin school will be subject to the passing haulage. Below is an extract from the Monaghan County Council Environment & Heritage Landscape Policies; ENV 2. ENV 3. ENV 4. Prepare a County Landscape Character Assessment in accordance with the requirements of Landscape and Landscape Assessment Consultation Draft Guidelines for Planning Authorities, DOELG,June 2000. Protect the landscapes and natural environments of the county by ensuring that any new developments in designated sensitive rural landscapes do not detrimentally impact on the character, integrity, distinctiveness or scenic value of the area. Sustain, conserve,manage and enhance the landscape diversity,character and quality of the County for the benefits of current and future generations. Zone important landscape features and elevated lands within settlements as Local Landscape Policy Areas (LLPAs)9, to ensure that developments do not detrimentally impact on the amenity of the landscape nor on the natural setting of settlements. I URGE YOU AS PLANNERS TO ADHERE TO YOUR OWN POLICIES. The Stream Bioenergy EIAR VOL1 section 4.1.1 Population and health sensitivity within study area. The study opens with 4.1.1 Existing Environment Population and Health Sensitivity within Study Area In a desk -based assessment of Population Health Sensitivity, And continues; While a general study area of ED's within 1 km from the site location is included for population statistics, the wider area of 2.5 km from the site location has been used to inform the baseline description of the area. The "desk -based assessment" is wholly inaccurate either based on a lack of information or on an area adjusted to reveal the required result. With my limited knowledge of local residents' personal information, I know of at least three households within 500 metres having residents with serious medical conditions. Although I feel I shouldn't comment on others personal information I can state that in our house (480M from proposed plant), my wife has Multiple Sclerosis and as a result is a permanent wheel chair user. She also has Arterial Sclerosis and Arterial Fibrillation, breathing difficulties and other medical issues. This results in a limited amount of her time being able to be enjoyed outdoors. This will have a detrimental effect on Maxine's mental health. The construction and subsequent operation of the proposed A D plant would reduce the already low quality of life further due to the odours, insect infestations and noise and resulting in even less time being spent outdoors. As previously mentioned, it will not be possible to stop these odours & pests permeating our homes even if living with windows permanently closed. It is noted that the closest residence to the proposed plant is home to a young family and that their play area directly borders the proposed plant, evident by the swings, slide, play house, pool, football nets, lawn etc. I have been told proudly and directly that the occupants are "the third generation on that land, the family residing there for over 100 years and have absolutely no intention of moving". In such case I would also like to object on their behalf due to the drastically reduced quality of home life and the potential effects on mental and physical development that the proposed installation would have on the young members of the family. Decision makers please take note of the following. Extracts from EIAR VOLIII 9-10, regarding Drumlins / Moraine fields; This ribbed moraine field is not only unusual in its huge size and the size of individual features around Rockcorry and Cootehill, but because they are interspersed with thick peat deposits the features are quite striking. They form the perfect 'ribbed' topography Site Importance — County Geological Site; recommended for Geological NHA These are the largest individual ribbed moraine features anywhere in the world and therefore one of the most important geological terrains in Ireland. I would like to suggest that prior to ecological evaluations being carried out the nature of the land was dramatically altered by the removal of hedging, and digging out of bog on the lower sections of fields. The section below from the biodiversity report that reads "limited Iiivr,rhy dire io management and lack of suitable conditions for amphibians or other projected iouiia". It should read due to habitat removed as a pre-emptive measure prior to inspection. It has been noted that recently (Feb' 2026) hedging has been replaced at the ring fort. Was this replacement approved? Was it overseen by the relevant authorities? Has a fine been administered for its illegal prior removal? The ring fort and its curtilage are legally protected under the national monuments act 1930-2004 Overall, the ecological evaluation indicates that the project area predominantly supports habitats and species of low to moderate local value. Hedgerows and treelines provide some connectivity and foraging opportunities for bats and common passerines, but no evidence of Annex I or II species was recorded. Drainage ditches and improved agricultural grassland offer limited biodiversity due to management and lack of suitable conditions for amphibians or other protected fauna. Overall, the site is largely of local ecological importance only, with no features of high or regional significance identified. In actual fact the common Lizard (Zootoca vivipara) have been spotted on these fields, Ref Martin McCaul- Drumcall. Bats & birds of prey are commonly seen. This application is ill advised and would be incorrectly located, causing physical irreversible harm to the landscape and personal suffering to local residents for the rest of their lives. I strongly urge you to deny this planning application. Yours faithfully J K Crowe.