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HomeMy WebLinkAbout2660018 - F.I. Request Letter 24/03/2026 Stream BioEnergy Ireland Limited C/O Rachel Condon McCutcheon Halley Kreston House, Arran Quay, Dublin 7 D07 K271 Re: Planning and Development Act 2000 (as amended). Planning and Development Regulations 2001 (as amended). 26/60018 - permission for the proposed development consisting of: i. A 10-year permission for a Renewable Biogas Plant and associated road improvements, on a site of approximately 6.2 hectares located immediately west of the R189 Road and south of the L2280 Road, on lands in the townlands of Maghernakelly and Drumcall, Co. Monaghan. The proposed Plant will generate renewable biogas from 99,000 tonnes per annum of poultry manure, along with other biodegradable agricultural and agri-food organic materials, utilising anaerobic digestion technology. The development will consist of: a) Buildings and associated Structures: Administration Building (432sq.m GFA and approx. 5.94m High (h); Main Process Building (9,104sq.m GFA and approx. 12.58m-14.91m h) with odour control system and associated dispersion stack approx. 40m h; Digestate Dryer Building (972sq.m GFA and approx. 16.54m h); Pellet Storage & Distribution Building (875sq.m GFA and approx. 12.34m h); a Combined Heat and Power Building (368.5sq.m GFA and approx. 10.01m h); Control Building (183.1sq.m GFA and approx. 5.57m h); Containerised Boiler (approx. 5.44m h); a Combined Dryer/Boiler/CHP dispersion stack approx. 20m h); and a Plant Room (22sq.m GFA and approx. 4.75m h). b) Bunded Tank Farm: including a Digestate Treatment Plant (approx. 20m h); 6 no. Digester Tanks (approx. 27.86m h); a Sludge Buffer Tank (approx. 18.1m h); an Evaporator Feed Tank (approx. 12.1m h); a Condensate Tank (approx. 10.6m h); a Concentrate Tank (approx. 10.6m h); a Hot Water Tank (approx. 5.6m h); 2 no. Ammonia Strippers (approx. 9m h); 2 no. Desulphurisation Units (approx. 14m h); 2 no. Activated Carbon Units (approx. 5m h); a Gas Holder (approx. 10.65m h) with 4 no. approx. 13m high lightning rods. c) A CO2 Liquefaction Plant (approx. 14.6m h); a Biogas Upgrade Plant (approx. 10.85m h); 4 no. Fan Coolers (approx. 2.2m H); a Flare Unit (approx. 10.1m H); a Fuel Storage Tank (approx. 1.85m h); a Gas Grid Entry Unit (approx. 5.1m h); a Firewater Tank (approx. 10.1m h); 3 no. LPG Tanks (approx. 3.8m h); 5 no. Feedstock Storage Tanks (approx. 9.5m h); an undergrounded Water Tank; a backup generator (approx. 2.6m h). d) Provision of 35 car parking spaces and a covered cycle parking area. e) A new vehicular access to the biogas facility from the northern site boundary, connecting to the L2280, designed to provide safe and efficient access for all vehicle types. f) Local road improvement works to the L2280, including widening and realignment of approximately 200 metres of the existing carriageway, and reconfiguration of the L2280 / R189 junction. g) All ancillary site development works and services, including two wheel washes, two weighbridges, landscaping and screening berms, boundary fencing and retaining walls, site lighting, surface water drainage and attenuation tanks, a foul effluent collection system, two entrance signs and one directional sign, a service yard, internal circulation routes, pipe bridges, access stairs and footpaths, and all associated site development and infrastructural works. ii. Reprofiling of an approximately 2.6 hectares agricultural field east of the R189 Road and south of the L2320 Road, in the townlands of Maghernakelly and Drumgole, Drum, Co. Monaghan to improve land levels for continued agricultural use, utilising excess material generated from the site formation of the proposed Renewable Biogas Plant. An Environmental Impact Assessment Report (EIAR) has been prepared and will be submitted to the Planning Authority with the application. The EIAR will be available for inspection or purchase at a fee not exceeding the reasonable cost of making a copy during the office hours of the Planning Authority. Associated Gas Grid Connection: Biogas will be upgraded to biomethane within the Renewable Biogas Plant and injected into the national gas grid via an associated gas grid connection. The gas pipeline route to be delivered separately by Gas Networks Ireland under the Section 39A consent process (CRU-regulated) would be located within the public road corridor (R189 and R188) through the townlands of Maghernakelly, Dernamoyle, Drumgarkin, Dyan, Freame Mount Demesne, Dawson Grove Demesne and Dromore West, Co. Monaghan. This infrastructure is assessed in the EIAR, but permission is not sought under this application at this site of approximately 8.8 hectares in the townlands of Maghernakelly, Drumcall and Drumgole, Drum Co. Monaghan. _______________________________________________________ Dear Sir/Madam, With reference to the above application, I am to inform you that the information submitted is not adequate to enable a decision to be made. In accordance with the provisions of Article 33 of the Planning and Development Regulations 2001 (as amended) you are hereby requested to submit further information as set out on the attached page. Article 33(3) states that “where a requirement under sub-article (1) or sub-article (2) (Clarification) is not complied with within the period of 6 months from the date of the requirement for further information, or such additional period, not exceeding 3 months, as may be agreed by the Planning Authority, the planning application shall be declared to be withdrawn”. It should be noted that you will be required to give notice in an approved newspaper under article 35(1)(a) and erect a site notice in accordance with Article 35 (1)(b) of the Planning and Development Regulations 2001 (as amended) if the further information received is considered to contain significant additional data. Please Note: 4 copies of Additional Information to be submitted. In the case of Significantly Different Information, 6 copies of additional information to be submitted. Yours faithfully, __________________________ ADMINISTRATIVE OFFICER pp 26/60018 Stream BioEnergy Ireland Limited This site of approximately 8.8 hectares in the townlands of Maghernakelly, Drumcall and Drumgole, Drum, Co. Monaghan ADDITIONAL INFORMATION 1. EU Directive 2014/52/EU requires that Environmental Impact Assessment Reports (EIAR’s) shall identify, describe and assess in an appropriate manner, in the light of each individual case, the direct and indirect significant effects of a project on the following factors: a) Population and human health b) Biodiversity with particular attention to species and habitats protected under Directive 92/42/EEC and Directive 2009/147/EC c) Land, soil, water and climate d) Material assets, cultural heritage and the landscape e) The interaction between the factors referred to in points (a) to(d) Notwithstanding the information provided, in order for the Planning Authority to fully understand the full range of potential environmental impacts arising from the proposed development, the applicant is requested to provide additional information which clearly demonstrates how the submitted EIAR complies with item (e) above i.e. ‘The interaction between the factors referred to in points (a) to (d)’. The information submitted shall list all identified interactions/interrelationships anticipated between the various specialist topic headings (i.e. Chapter 4 to Chapter 16 of the EIAR) and the associated significance of each effect/impact. The information shall include all direct, indirect, cumulative, and residual impacts/effects caused as result of these interactions at both the construction and operational stage of the proposed development. 2. In the interests of environmental protection, the applicant is requested to provide the following information; a) Confirmation of Environmental Impact Assessment screening from the Department of Agriculture Food & the Marine (DAFM) for the recontouring an area of 2.6 hectares with soil from the Renewable Energy Development construction site. b) An agricultural improvement plan, prepared by a suitably qualified agricultural advisor, detailing how the land will benefit from infilling in terms of agricultural use and how it will improve upon current farm management requirements. c) A hydrogeological risk assessment to demonstrate how the hydrological balance of surrounding, higher-quality intact bog areas may, or may not be affected. The submitted assessment shall have particular regard to areas of cutover peat at the soil relocation site. d) Confirmation that 18,600m3 of fill (m3) is the maximum amount of fill to be relocated from the construction site. The applicant shall also provide clarification on how this figure has been arrived at and confirmation of the equivalent amounts in tonnes. 3. Policy PMP 1 of Section 6.18.1 ‘Record of Monuments and Place’ of the Monaghan County Development Plan 2025-2031 states that ‘development adjacent to an archaeological monument or site will only be acceptable where it is sited in a manner which minimises the impact on the monument and its setting. Development which is likely to have an adverse impact upon an archaeological monument or site, or its setting shall be resisted’. Planning Authority notes the submission of an Archaeological Testing Report (24E1224), including the results a Geophysical Survey (24R0379) (EIAR Vol II Ch.15). The Department of Housing Local Government and Heritage (DHLGH) have reviewed same and note that the geophysical survey revealed an area of prehistoric activity suggesting there is a high potential for further unknown sub-surface archaeological remains within the application site. Having regard to same, DHLGH recommends that a programme of further archaeological testing, including full excavation of the feature identified in archaeological testing, be carried out. In particular, with regard to previously unrecorded Archaeological Areas, DHLGH recommends ‘that the archaeological areas ‘Area (AA)1 Trench 6’ be extended and cleaned back to reveal the full extent of all archaeological feature on the site. These features shall be fully archaeologically recorded, planned, photographed and excavated prior to the commencement of works, and in keeping with Best Archaeological Practice under licence and agreement with the Department’. DHLGH also requests that the applicant to comply with the following; • ‘Engage the services of a suitably qualified archaeologist (licensed under the National Monuments Acts 1930–2004) to carry out pre-development testing over the entire site. No sub-surface work shall be undertaken in the absence of the archaeologist without his/her express consent. • The archaeologist is required to notify the Department of Housing, Local Government and Heritage in writing at least four weeks prior to the commencement of site preparations. This will allow the archaeologist sufficient time to obtain a licence/consent to carry out the work. • The archaeologist shall carry out any relevant documentary research and may excavate test trenches at locations chosen by the archaeologist, having consulted the proposed development plans. • Archaeological testing shall be informed and supplemented by licensed metal detection survey. • Having completed the work, the archaeologist should submit a written report to the Planning Authority and to the Department of Housing, Local Government and Heritage in advance of the planning decision. Where archaeological material/features are shown to be present, preservation in situ, preservation by record (excavation) or monitoring may be required. It should be borne in mind that, if significant archaeological remains are found, refusal might still be recommended, and/or further monitoring or excavation required’. The applicant is requested to review the full content of the DHLGH submission and respond accordingly to the issues raised. 4. In addition to item 3 above, Monaghan County Council Heritage Section have reviewed the proposal and have raised concerns about the potential impact the proposal would have on the setting of Recorded Monument MO022-008, (Hilltop enclosure). In particular, Heritage Section notes the following; ‘Given the monument’s high cultural significance and sensitivity, the proximity of the proposed development, combined with its considerable scale, height, and massing, would independently and cumulatively generate a substantial negative impact on its setting. The new structures would compete visually with the hillfort, obscuring or overwhelming views from various directions and appearing incongruous within the historic rural context. Tree planting or earthen berms cannot be relied upon as mitigation, as deciduous planting offers no screening in winter and may fail or be removed through weather events or maintenance practices.’ Heritage Section also notes that ‘The proposed development would significantly disrupt the intervisibility between this important prehistoric monument and the prehistoric stone row at Drumgole (Droim Gabhla), known locally as the “Grey Stones.” Introducing an industrial-scale development into what is currently an unspoilt rural landscape would cause a profound adverse impact on the monument’s setting, character, and legibility. It would also interrupt established visual relationships between several recorded monuments in the surrounding landscape.’ The applicant is requested to respond to the comments made by Heritage Section and seek to demonstrate how the proposal fully complies with aforementioned Policy PMP 1 and Section 6.18.1 ‘Record of Monuments and Places’ of the Monaghan County Development Plan 2025-2031. 5. Policy DLP 1 of the Monaghan County Development Plan 2025-2031 states “To ensure that any new development will not adversely affect the site, setting or views to and from historic houses, gardens and designed landscapes”. Furthermore, Policy DLP 2 states “To require that any proposals for new development in the vicinity of historic houses or demesnes landscapes are accompanied by an evaluation of the impact of the development on the landscape, designed views and vistas to /from such a site.” Having reviewed the proposed development, Monaghan County Council Heritage Section, having regard to these policies and also Policy PMP1 has responded as follows:- ...In terms of built heritage, the remnants of the post medieval New Park landed estate is located directly to the south of the proposed development site. On early OS maps it is clear that there was an extensive designed landscape surrounding this big house. The extent of survival of features within the house and farm cluster which still exists on the site is not clear from the EIAR. Nevertheless, the proposed development would have a very significant impact on any surviving remnants of this estate.’ The applicant is requested to respond to the comments made by Heritage Section and seek to demonstrate how the proposal fully complies with aforementioned Policies PMP 1, DLP 1 and DLP 2 of the Monaghan County Development Plan 2025-2031. 6. The Planning Authority notes that the applicant proposes to utilise an existing farm entrance onto the Local Primary Road L-2320 to access the proposed soil relocation area. It has not been demonstrated however, how this existing entrance meets the minimum visibility standards for the intensification of an existing access onto a non-urban road. In the interests of road safety, the applicant is required to submit the following information in accordance with section 15.23 ‘Road Access Standards’ and 15.23.2 ‘Minimum Visibility Standards for Non-Urban Roads’ of the Monaghan County Development Plan 2025-2031; a) A site layout plan (1:500 scale) indicating how a clear and unobstructed visibility splay of 70 metres can be achieved at the proposed entry/exit point onto the adjoining public road from the soil relocation area. The required visibility splays should be provided from a point in the centre of the entrance, 2.4 metres from the road edge at a height of 1.05 metre to 2.0 metres above ground level to an object height of 1.05 metres to 2.0 metres above ground level in both directions. The submitted site layout plan should demonstrate all necessary site work, including the extent of the front boundary hedge and trees which would be required to be removed/trimmed, re- grading of side banks etc to achieve the required sight distances. b) Where the sight distances are not achievable within the applicant’s ownership, the applicant should submit legal agreements with adjoining landowners giving their consent for all necessary works to facilitate the required 70 metres sight distances, including removal/trimming of hedgerow/hedges, re-grading of side banks etc. The Applicant should note that legal agreements should be submitted using the Appendix 13 template ‘Form of Agreement in respect of forward and rear visibility’ Appendix 13 and that the legal agreement and accompanying maps shall be signed by all parties and witnessed by a Solicitor. 7. Criterion (g) of section 15.22.4 ‘Landscaping and Boundary Treatment’ of the Monaghan County Development Plan 2025-2031 stipulates that ‘Where removal of extensive hedgerow and trees is proposed, existing site boundaries shall be supplemented, where new site boundaries need to be created, or where landscape mounds are proposed, a costed landscape plan, prepared by a suitably qualified, competent, technical professional with landscaping expertise shall be submitted where appropriate. A bond may be applied in the event of a grant of permission to ensure the satisfactory completion of the landscaping.’ Having regard to the significant hedgerow removal and the extensive earth berms proposed, the applicant is requested to submit a costed landscaping plan for the proposed development. 8. a) Policy CP 1 Monaghan County Development Plan 2025-2031 requires car parking proposals for all development proposal to comply with Section 15.24 ‘Car Parking Standards’ of the Monaghan County Development Plan 2025-2031. Whilst it is acknowledged Table 15.5 does not include a specific standard for the type of development proposed, the applicant is requested to provide additional information to justify the quantum of parking proposed, having regard to the parking standards relative to similar types of development listed under Table 15.5. Submitted details should also include specific carparking data in respect of similar facilities to that being proposed. b) Section 6.8.1.3, Chapter 6 ‘Traffic and Transport’ of the submitted EIAR notes that swept path turning assessments have been undertaken which demonstrate that the internal circulation route will ‘function satisfactorily for the volume of traffic likely to be generated by the development’. Planning authority notes that this statement is not supported by way of complementary maps. The applicant is therefore requested to provide a swept path assessment site layout plan to demonstrate same. Submitted details should have regard to Fire and Building Control requirements in respect of Fire Brigade Vehicle access (please see Clause 5.4 of Technical Guidance Document Part B Fire Safety 2024). c) Planning Authority notes that the Chapter 6 ‘Traffic and Transport’ of the submitted EIAR incorrectly refers to ‘Appendix 16.1’ and ‘Appendix 16.2’ which do not exist. The applicant is requested to provide clarification with regard to same. 9. An Taisce have commented on the proposed development and have raised several concerns under the headings of; i. Feedstocks ii. Methane Leakage iii. End- Use of Digestate iv. Fossil Gas Lock-in v. Wetland proximity vi. Traffic Impact Assessment The applicant is requested to review the full content of An Taisce’s submission and provide a detailed and comprehensive response to each issue raised. 10. A significant number of third-party submissions (26 No.) have been received with respect to the development proposed. The applicant is requested to review the content of same and provide a detailed and comprehensive response to each of the matters contained within each submission. Note: The applicant is advised to consult with the relevant sections of the Planning Authority prior to making a formal response to this Further Information request. The planner dealing with this application is Brian McGeary