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