HomeMy WebLinkAbout2660018 - F.I. Received Doc. - McCutcheon Halley Chartered Planning Consultants Response
Response to Further
Information Request
Proposed Development of Renewable Biogas Plant at
the site in the townlands of Maghernakelly &
Drumcall, Drum, Co. Monaghan
on behalf of Stream BioEnergy Ireland Limited
August 2026 RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Document Control Sheet
Client Stream BioEnergy Ireland Limited
Project Title Monaghan Renewable Biogas Plant
Document Title Response to Further Information
Request
Document Comprises
Volumes -
Pages
(Including Cover) 33
Appendices 2
Prepared by Ignatius Lo
Checked by Paula Glavin
Office of Issue Dublin
Document Information
Revision A
Status Final
Issue Date August 2026
DUBLIN
Kreston House
Arran Court
Arran Quay
Dublin 7
D07 K271
T. +353 (0)1 804 4477
CORK
6 Joyce House
Barrack Square
Ballincollig
Cork
P31 YX97
T. +353 (0)21 420 8710 www.mhplanning.ie RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Contents
1. Introduction ............................................................................................... 3
1.1 Consultation with Monaghan County Council .................................. 4
1.2 Effect of Removal of the Soil Relocation Area on the FI .................. 4
1.3 Additional archaeological investigation ............................................ 5
1.4 Scope of Revised Documentation ...................................................... 5
1.4.2 Environmental Impact Assessment Report .................................. 6
1.4.3 Appropriate Assessment Screening Report ................................. 7
1.4.4 Other Supporting Documentation ................................................ 8
1.4.5 Drawings ........................................................................................... 8
1.5 Planning Statement .............................................................................. 9
2. Response to Further Information Request .......................................... 10
2.1 Further Information Request Point 1 .............................................. 10
2.2 Further Information Request Point 2 .............................................. 11
2.2.6 DAFM Screening ............................................................................. 11
2.2.7 Agriculture ...................................................................................... 12
2.2.8 Hydrology/Bog ............................................................................... 12
2.2.9 Fill volumes ..................................................................................... 13
2.3 Further Information Request Point 3 .............................................. 14
2.4 Further Information Request Point 4 .............................................. 17
2.5 Further Information Request Point 5 .............................................. 19
2.6 Further Information Request Point 6 .............................................. 21
2.7 Further Information Request Point 7 .............................................. 22
2.8 Further Information Request Point 8 .............................................. 23
2.8.10 Car Parking ................................................................................. 23
2.8.11 Vehicle Swept Path Assessments ............................................ 27
2.8.12 EIAR clarity .................................................................................. 28
2.9 Further Information Request Point 9 .............................................. 28
2.10 Further Information Request Point 10 ............................................ 30
3. Conclusion ............................................................................................... 31
RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
1. Introduction
This Further Information submission has been prepared by McCutcheon
Halley Chartered Planning Consultants (MHP) on behalf of Stream BioEnergy
Ireland Limited in response to the Request for Further Information issued by
Monaghan County Council on 24 March 2026 in respect of Planning Reg. Ref.
26/60018.
The Further Information request raised a range of matters relating to the
environmental assessment of the Proposed Project, and specifically, the
proposed Soil Relocation Area, archaeology and cultural heritage, landscape,
access and traffic, parking, and the matters raised in submissions received
on the application. In issuing the request, the Planning Authority specifically
advised the Applicant to consult with the relevant sections of Monaghan
County Council prior to making its formal response.
The Applicant has taken that opportunity to undertake a comprehensive
review of the application rather than respond to the individual Further
Information items in isolation. Since receipt of the request, the project team
has engaged directly with the Planning Authority and relevant Council
representatives, undertaken additional field investigation and specialist
assessment, reviewed the design and construction methodology, and
updated the EIAR and supporting application documentation to ensure that
the Further Information response is based upon a single, consistent and fully
assessed revised proposal.
The main amendment arising from this process is the removal of the
approximately 2.6 hectare Soil Relocation Area previously proposed east of
the R189. The application proposed the reprofiling of that agricultural field
using surplus excavated soil and stone generated during construction of the
Renewable Biogas Plant. Following consideration of Item 2 of the Further
Information request and engagement with the Planning Authority, the
Applicant reviewed the need to retain this element of the application.
The Soil Relocation Area is not required for the operation or functioning of
the Renewable Biogas Plant. An alternative means of managing the surplus
excavated material is available through its removal by suitably authorised
contractors for appropriate reuse, recovery or disposal at an appropriately
authorised receiving facility. The Applicant therefore elected to omit the
separate land reprofiling element from the application. This approach
simplifies the physical extent of the Proposed Development and removes the
separate construction activity and access associated with the eastern
agricultural field.
For clarity, the decision to remove the Soil Relocation Area does not arise
from any conclusion that the eastern field is environmentally unsuitable for
the works originally proposed or that unacceptable environmental effects
had been established. Rather, it represents a refinement of the application
whereby an ancillary element that is not necessary to the functioning of the
Renewable Biogas Plant has been omitted and the surplus material will RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
instead be managed through the established authorised waste /resource-
management system.
The revised Proposed Development is consequently confined to the
Renewable Biogas Plant and associated works for which planning permission
is sought. The eastern field is no longer part of the proposed development
for which consent is sought.
1.1 Consultation with Monaghan County Council
Following receipt of the Further Information request, the Applicant and
project team commenced direct engagement with Monaghan County Council
in accordance with the Planning Authority's invitation to consult with the
relevant Council sections.
An initial meeting was held on the 27th of April 2026 to discuss the Further
Information request and the appropriate approach to the matters raised. The
meeting was attended by representatives of the Council's Planning,
Environment, Heritage and Roads sections, as relevant to the individual
Further Information items.
The Planning Authority subsequently confirmed that, where no development
was proposed within the Soil Relocation Area, the eastern field should be
removed from the red line boundary so that the application clearly reflected
the revised proposal. The Council also confirmed that the amendment would
likely constitute Significant Further Information and that the revised
development description should therefore be reflected in the Significant
Further Information site and newspaper notices.
The Council further noted that the requirements of Items 2(a) and 2(b), which
related specifically to DAFM EIA screening and preparation of an Agricultural
Improvement Plan for the former Soil Relocation Area, would no longer arise
where the reprofiling proposal was omitted.
A further meeting was held in August 2026 with representatives from the
Planning Authority and Heritage, together with relevant members of the
project team, at which progress on the Further Information response, the
revised proposal and the additional technical work were discussed.
This engagement has informed the scope and presentation of the Further
Information response; the Applicant nevertheless recognises that the
application falls to be determined by the Planning Authority having regard to
the full planning and environmental assessment now submitted.
1.2 Effect of Removal of the Soil Relocation Area on the FI
The removal of the Soil Relocation Area has a direct bearing on a number of
the matters raised in the Further Information request. Items 2(a) and 2(b),
concerning DAFM screening and an Agricultural Improvement Plan for the RECEIVED: 28/08/2026
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Information Request
proposed reprofiling works, no longer arise. The aspects of Item 2(c) directed
specifically to the hydrological relationship between the former Soil
Relocation Area, cutover peat and surrounding bog lands similarly no longer
arise from the revised proposal, although the hydrological and
hydrogeological assessment of the Renewable Biogas Plant itself has been
reviewed and updated. Item 2(d), concerning the quantity and derivation of
surplus excavated material, remains relevant and is addressed in full.
Item 6 of the Further Information request related exclusively to the proposed
construction access from the L2320 serving the former Soil Relocation Area.
As that element has been removed, no development related traffic will use
that access and the requirement for visibility splays and associated third -
party agreements no longer arises.
The remaining Further Information items continue to apply and have been
addressed through additional information, further field investigation,
specialist assessment and/or revisions to the EIAR and supporting
documents.
1.3 Additional archaeological investigation
A substantial programme of additional archaeological investigation has been
undertaken in response to Item 3. Following consultation with the National
Monuments Service, further archaeological testing was undertaken under
Licence No. 26E0370. Eleven additional trenches, totalling approximately 360
linear metres, were excavated across Fields 1 and 2, including areas where
no archaeological anomalies had previously been identified. The previously
excavated Trench 6 was also extended to establish the full extent and
character of Archaeological Area AA1.
The additional testing confirmed AA1 as a small and already truncated burnt
mound/fulacht fia deposit with a possible associated trough. The burnt
mound spread was defined as approximately 3m by 2.8 m and approximately
0.10m in average depth and had been truncated by a modern linear ditch.
Importantly, no additional archaeological features or finds were identified
elsewhere within the Proposed Development site.
The archaeological resource within the site is therefore now substantially
better understood than at the time of the original application. The updated
Cultural Heritage assessment provides for preservation by record of AA1
through licensed archaeological excavation prior to the relevant construction
works, together with archaeological monitoring of topsoil stripping and initial
ground disturbance across the remainder of the Renewable Biogas Plant site.
1.4 Scope of Revised Documentation
The Further Information submission comprises a coordinated suite of revised
and additional documentation. Documents have been revised where the RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
removal of the Soil Relocation Area, additional fieldwork, further technical
analysis or the specific matters raised by the Planning Authority necessitate
an amendment. Documents which remain technically valid have not been
unnecessarily reproduced.
1.4.2 Environmental Impact Assessment Report
The EIAR has been comprehensively reviewed to ensure that the project
description, assessment assumptions, mitigation, monitoring, interactions
and residual effect conclusions consistently relate to the revised Proposed
Project. Amendments arising from the Further Information process are
identified within the revised EIAR for ease of review.
• Volume I - updated Non-Technical Summary
• Volume II - updated Chapters 1-17 and new Chapter 18
o revised Chapter 1 Introduction, including explanation of the
FI process and updated EIAR;
o revised Chapter 2 Project Description, including removal of
the SRA and revised soil management arrangements;
o revised Chapter 3 Alternatives, recording the design
evolution associated with off site management of surplus
material;
o revised Chapter 4-16: updated specialist chapters;
o revised Chapter 17 Summary of Mitigation and Monitoring;
o Chapter 18: Interactions, dealing expressly with FI Item 1. The
original EIAR considered interactions between environmental
factors within the individual specialist chapters. In response
to Item 1 of the Further Information request, these
assessments have now been brought together in a dedicated
Chapter 18 – Interactions. This provides a consolidated
assessment of the relevant interrelationships, their
significance and the associated direct, indirect, cumulative
and residual effects during construction and operation. The
exercise has also included a further cross disciplinary review
to ensure that the interaction assessment reflects the revised
Proposed Project and the updated specialist assessments
prepared following the Further Information request.
The EIAR appendices (Volume III) have been reviewed as part of the Further
Information process having regard to the revised Proposed Project and the
additional technical assessment undertaken. Not all appendices required
revision. Where an appendix remains applicable and its findings are
unaffected by the changes to the Proposed Development, the originally
submitted appendix continues to be relied upon.
Volume III therefore comprises a combination of new and updated
appendices, together with the original appendices that remain unchanged RECEIVED: 28/08/2026
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and continue to form part of the EIAR. For clarity, where an appendix has
been revised or replaced as part of this Further Information response, the
updated version supersedes the corresponding appendix originally
submitted.
The principal new and updated appendices submitted as part of this Further
Information response include:
• Appendix 2-1: Updated Outline Construction Environmental
Management Plan, including the Soil and Surface Water Management
Plan
• Appendix 8-1: Updated Resource Waste Management Plan
• Appendix 10-2: Updated Flood Risk Assessment
• Appendix 10-3: Updated Water Framework Directive Assessment
Appendix 15-6: New Additional Archaeological Testing Report
In conclusion, the EIAR has been reviewed and updated having regard to the
revised Proposed Project and the additional technical information prepared
in response to the Further Information request. The updated assessments
do not identify any new or materially different significant environmental
effects beyond those identified and assessed in the revised EIAR.
1.4.3 Appropriate Assessment Screening Report
The Appropriate Assessment Screening Report submitted with the
application has been reviewed and updated as part of the Further
Information process to ensure that the assessment reflects the revised
Proposed Project. In particular, the assessment has been revised to reflect
the removal of the former Soil Relocation Area, the final project definition
comprising the Renewable Biogas Plant together with the separately
delivered Linear Gas Grid Connection and the findings of the updated Water,
Water Framework Directive, Air Quality, Biodiversity and other relevant
technical assessments.
The updated screening has also revisited the potential source–pathway–
receptor relationships between the Proposed Project and European Sites.
The assessment confirms that there is no credible pathway capable of giving
rise to likely significant effects on Kilroosky Lough Cluster Special Area of
Conservation (SAC). A downstream hydrological pathway to Lough Oughter
and Associated Loughs SAC is acknowledged and has been assessed having
regard to the nature and scale of the potential sources, the approximately 38
km hydrological separation, the intervening receiving water network and the
findings of the updated Water Framework Directive and Water assessments.
The screening also considers potential atmospheric, disturbance and other
pathways, together with potential in-combination effects. The assessment RECEIVED: 28/08/2026
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August 2026 | Response to Further
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undertaken concludes that likely significant effects can be excluded on the
basis of objective scientific information.
In undertaking the updated screening, particular care has been taken to
distinguish between standard inherent characteristics of the Proposed
Project and generally applicable construction practices, which would form
part of the development irrespective of the presence of a European Site, and
any measure introduced specifically for the purpose of avoiding or reducing
an effect on a European Site. The Stage 1 conclusion does not rely upon
specific Natura 2000 mitigation.
Accordingly, the review undertaken as part of the Further Information
process does not alter the conclusion of the Appropriate Assessment
Screening Report. It can be excluded, on the basis of objective scientific
information, that the Proposed Project, either alone or in combination with
other plans or projects, will have a likely significant effect on a European Site.
The Proposed Project therefore does not require progression to Stage 2
Appropriate Assessment and a Natura Impact Statement is not required.
1.4.4 Other Supporting Documentation
Other supporting information included with this Further Information
• Hydrogeological Risk Assessment – Hydro Environmental Services
(Attachment A)
• Landscape Management & Maintenance Schedule - Macroworks
(Attachment B)
• Revised Engineering Services Report including swept-path drawings
as requested (Attachment C)
• Revised Photomontages with additional CHVP2 - Stone Row (MO017-
068) in Drumgole as requested (Attachment D)
• Revised Appropriate Assessmetn Screening Report (Attachment E)
• Revised Water Protection Plan Checklist (Attachment F)
1.4.5 Revised Drawings
Architectural – Revised Drawings
Drawing No. Drawing Title Scale Page
Size
4192 - PL01 Revision B Site Location Map 1:2500 A3
4192 - PL02 Revision B Existing Site Layout Plan 1:500 A0
4192 - PL03 Revision B Proposed Site Layout Plan 1:500 A0
4192 - PL04 Revision B Contextual Site Plan - Sections 1:1000 A0
4192 - PL06 Revision A Existing & Proposed Site Sections D-D, E-E 1:500 A0
RECEIVED: 28/08/2026
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Engineering – Revised Drawings
Drawing No. Drawing Title Scale Page
Size
1102-P11 Proposed Retaining Structures 1:500 A1
1200-P04 Site Cross Section - Proposed Retaining
Structures
1:500 A1
2001-P05 Proposed Storm Drainage Layout 1:500 A1
2002-P05 Proposed Foul Drainage Layout 1:500 A1
2101-P04 Proposed Watermains 1:500 A1
Transport – Revised Drawings
Drawing No. Drawing Title Scale Page
Size
03208/PL01 Revision A Proposed Road Improvement & Access -
Proposed Junction Upgrade
1:500 A1
03208/PL02 Revision A Proposed Road Improvement & Access -
Swept Path Assessment
1:200 A1
Landscape – Revised Drawings
Drawing No. Drawing Title Scale Page
Size
LD.DRM 1.1 Landscape Mitigation Plan 1:1000 A1
1.5 Planning Statement
The Planning Statement submitted with the original application has not been
reissued as part of this Further Information response. The planning policy
assessment contained within that document remains applicable to the
revised Proposed Development.
The removal of the Soil Relocation Area does not alter the nature, scale,
capacity or function of the Renewable Biogas Plant, the principle of the
proposed use, the planning policy framework applicable to the plant, or the
strategic planning considerations supporting the development. The revised
proposal is narrower in physical extent by virtue of the omission of an
ancillary agricultural land reprofiling element.
Where the original Planning Statement refers specifically to the Soil
Relocation Area, those references should now be read as superseded by the
revised development description, EIAR and this Further Information
response. The planning matters arising directly from the Further Information
request, including compliance with Policies PMP 1, DLP 1, DLP 2, CP 1 and the
relevant development-management provisions, are addressed expressly
within this Further Information Response Report.
Accordingly, it was not considered necessary or helpful to reproduce the full
Planning Statement where the substantive policy assessment of the RECEIVED: 28/08/2026
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Renewable Biogas Plant remains unchanged. The original Planning
Statement should instead be read together with, and subject to, the revised
application documentation and this Further Information response.
For the avoidance of doubt, where there is any inconsistency between the
originally submitted documentation and the revised documents forming part
of this Significant Further Information response, the revised documentation
submitted with this response shall prevail.
2. Response to Further Information
Request
2.1 Further Information Request Point 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 inter actions at
both the construction and operational stage of the proposed development.
Response
This response should be read in conjunction with Chapter 18 Interactions in
the EIAR (Volume II).
The potential for interactions between environmental factors was considered
in the EIAR originally submitted with the application through the individual
specialist assessments contained in Chapters 4 to 16. Each specialist author
considered, as relevant to their respective topic, the relationship between
that environmental factor and other environmental disciplines, including the RECEIVED: 28/08/2026
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Information Request
potential for effects arising in one environmental topic to influence or
interact with effects identified in another.
In response to the Planning Authority's request, this assessment has now
been brought together and presented in a single consolidated chapter,
Chapter 18, Interactions. The chapter identifies the relevant interactions
between the specialist environmental topics, describes the nature of those
interactions and sets out the significance of the associated effects, including
direct, indirect, cumulative and residual effects during both the construction
and operational phases.
Importantly, the preparation of the consolidated Interactions chapter has
also provided an opportunity to undertake a further project wide review of
the EIAR following the refinement of the Proposed Development through the
Further Information process. The assessment therefore reflects the revised
Proposed Project, including the removal of the former Soil Relocation Area
and the technical assessments submitted as part of this Further Information
response.
The revised specialist chapters have been reviewed together to ensure that
the assumptions, impact assessments, mitigation measures, monitoring
requirements and residual effect conclusions are consistent across
disciplines and that any changes arising from the revised proposal have been
appropriately reflected in the assessment of interactions.
Chapter 18 should therefore be read as a consolidation and further
development of the interaction assessments undertaken by the individual
specialists, rather than as a separate environmental assessment undertaken
in isolation from the specialist chapters. It provides the Planning Authority
with a single, transparent overview of the environmental interactions
associated with the Proposed Project and their significance.
Having undertaken this review, no new or materially different significant
environmental effects have been identified as a consequence of the
interactions between environmental factors beyond those assessed in the
revised EIAR. The residual effects arising from relevant interactions are
identified and assessed in Chapter 18.
2.2 Further Information Request Point 2
In the interests of environmental protection, the applicant is requested to provide
the following information;
2.2.6 DAFM Screening
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. RECEIVED: 28/08/2026
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Information Request
Response
Following receipt of the Further Information request and subsequent review
of the proposal, the Applicant has removed the previously proposed Soil
Relocation Area from the Proposed Development. No recontouring, infilling
or other development is now proposed within the approximately 2.6 hectare
agricultural field east of the R189.
Suitable excavated soil and stone arising from construction of the Renewable
Biogas Plant will be reused within the development site where appropriate,
with the remaining surplus material removed off site by suitably authorised
contractors for appropriate reuse, recovery or disposal at an appropriately
authorised receiving facility.
Accordingly, as the agricultural land recontouring works which gave rise to
this item are no longer proposed, DAFM EIA screening in respect of those
works is no longer applicable to the revised Proposed Development.
The revised development description and arrangements for the
management of excavated soil and stone are set out in Chapter 2 Project
Description of the revised EIAR.
2.2.7 Agriculture
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.
Response
As outlined above, the previously proposed Soil Relocation Area has been
removed from the Proposed Development. The approximately 2.6 hectare
agricultural field will not be reprofiled or infilled as part of this application
and will remain in its existing agricultural use.
The Agricultural Improvement Plan requested under this item related
specifically to the justification and agricultural benefits of the proposed land
reprofiling works. As those works no longer form part of the revised
Proposed Development, an Agricultural Improvement Plan is no longer
required or relevant to the determination of the application.
The revised development description and arrangements for management of
surplus excavated soil and stone are set out in Chapter 2 Project Description
of the revised EIAR.
2.2.8 Hydrology/Bog
c) A hydrogeological risk assessment to demonstrate how the hydrological
balance of surrounding, higher-quality intact bog areas may, or may not RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
be affected. The submitted assessment shall have particular regard to
areas of cutover peat at the soil relocation site.
Response
This response should be read in conjunction with the report prepared by
Hydro Environmental Services (Attachment A) and Chapter 10 Water in the
EIAR (Volume II) together with its relevant appendices (Volume III)
Following removal of the Soil Relocation Area from the Proposed
Development, the aspects of this Further Information item relating
specifically to the proposed placement of soil within the former relocation
area and associated cutover peat no longer arise.
Notwithstanding this, the Applicant commissioned Hydro Environmental
Services (HES) to undertake a specific hydrological and hydrogeological
assessment of the retained Renewable Biogas Plant site , in order to establish
whether construction or operation of the revised Proposed Development has
the potential to affect the hydrological or hydrogeological regime of nearby
wetland areas. The assessment was prepared expressly in the context of the
revised proposal and omission of the Soil Relocation Area.
The assessment included a review of the geological, hydrological and
hydrogeological conditions of the site and surrounding area and specifically
considered the nearby Drumintin wetland, identified by HES as the only
surrounding bog or wetland feature with the potential to contain higher-
quality intact bog habitat. The assessment also considered the existing local
drainage network and potential surface water and groundwater connectivity
between the Renewable Biogas Plant site and the wetland.
HES concludes that, following removal of the Soil Relocation Area, there is no
identified hydrogeological linkage by which the revised Proposed
Development would alter the hydrological balance of Drumintin Wetland or
any other wetland feature in the surrounding area. The assessment further
concludes that the Proposed Development will not result in deterioration of
any Water Framework Directive quality element or compromise achievement
of the relevant WFD objectives.
The Hydrological and Hydrogeological Response to Further Information Item
2(c), prepared by Hydro-Environmental Services, is enclosed with this Further
Information response and should be read in conjunction with the revised
Chapter 10 – Water (Hydrology and Hydrogeology) and the updated Water
Framework Directive Assessment.
2.2.9 Fill volumes
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. RECEIVED: 28/08/2026
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Response
The earthworks quantities for the revised Proposed Development have been
reviewed and confirmed by the project Consulting Engineers, McAdam
Design, using the project earthworks model. The model is based on the
detailed topographical survey of the Renewable Biogas Plant site and the
proposed finished formation levels.
The earthworks model identifies approximately 98,420 m³ of excavated
material arising from site formation, foundations and associated
construction works. Of this material, approximately 79,900 m³ will be reused
within the Renewable Biogas Plant site for engineering fill, landscaping and
the formation of screening berms.
This results in a calculated net surplus of approximately 18,520 m³ of
excavated soil and stone. For the purposes of the environmental
assessments and construction planning, this quantity has been
conservatively rounded to approximately 18,600 m³. Accordingly,
approximately 18,600 m³ represents the assessed quantity of surplus
excavated soil and stone requiring removal from the Renewable Biogas Plant
site.
Following removal of the previously proposed Soil Relocation Area from the
Proposed Development, this surplus material will no longer be transferred to
the adjoining agricultural field. It will instead be removed off site by suitably
authorised contractors for appropriate reuse, recovery or disposal at an
appropriately authorised receiving facility or facilities, to be identified by the
appointed Contractor having regard to the relevant authorisation, available
capacity and material acceptance criteria.
Using a conservative indicative conversion factor of 1.8 tonnes per cubic
metre, approximately 18,600 m³ equates to 33,480 tonnes of surplus
material.
The revised earthworks quantities and arrangements for management of the
surplus excavated soil and stone are set out in Chapter 2 Project Description,
Chapter 9 Land, Soils and Geology, and the Resource and Waste
Management Plan submitted as part of this Further Information response.
2.3 Further Information Request Point 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 RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
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.
Response
This response should be read in conjunction with Chapter 15 of the EIAR
(Volume II) together with Appendix 15.6 (Volume III).
The submission of the Department of Housing, Local Government and
Heritage (DHLGH) has been reviewed in full, and a programme of additional
archaeological investigation has been undertaken in direct response to the
matters raised.
Consultation took place with the National Monuments Service (NMS),
including Senior Archaeologist Hugh Carey, on 20 March 2026 to agree an
appropriate strategy for the further archaeological investigation of the
Proposed Development site. Having regard to the nature of the archaeology RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
identified during the first phase of testing, the potential for the recovery of
metal artefacts was considered to be low. Accordingly, licensed metal
detection was not proposed as part of the Phase 2 methodology. The
proposed methodology was submitted to and agreed by the NMS and the
further archaeological testing was subsequently undertaken under Licence
No. 26E0370.
The further programme comprised 11 no. test trenches extending to
approximately 360 linear metres across Fields 1 and 2 of the Renewable
Biogas Plant site. The testing was deliberately extended into areas where no
archaeological anomalies had been identified during the earlier geophysical
survey in order to test and verify the robustness of those results.
In addition, the previously excavated Trench 6, within which Archaeological
Area AA1 had been identified during the first phase of testing, was extended
as part of the Phase 2 works to reveal and define the full extent of the
archaeological feature. The additional investigation confirmed AA1 as a
spread of burnt mound material with a possible associated trough, both of
which had been truncated by a modern linear ditch. The burnt mound spread
was defined as approximately 3 m east-west by 2.8 m north-south and
approximately 0.10 m in average depth.
Importantly, no additional archaeological features or finds were identified
elsewhere within the Proposed Development site as a result of this further
programme of investigation. The additional testing therefore provides a
substantially more comprehensive understanding of the archaeological
resource within the site and confirms that the identified archaeological
interest is confined to AA1.
The results of the further archaeological investigation are set out in the
Archaeological Testing Report prepared under Licence No. 26E0370, which is
presented in Appendix 15-6 of the EIAR (Volume III). The findings have also
been incorporated into the revised Chapter 15 Cultural Heritage of the EIAR.
Having regard to the confirmed presence and extent of AA1, the feature will
be subject to preservation by record through full licensed archaeological
excavation prior to commencement of the relevant construction works, in
accordance with the requirements of the National Monuments Service.
Following completion of the licensed excavation of AA1, topsoil stripping and
other initial ground disturbance across the remainder of the Renewable
Biogas Plant site will be subject to archaeological monitoring by a suitably
qualified archaeologist under the appropriate licence. Should any previously
unidentified archaeological material be encountered, works in the affected
area will cease pending assessment and consultation with the National
Monuments Service.
Accordingly, the Applicant has undertaken the additional pre-development
investigation requested by DHLGH, has established the nature and extent of
the archaeological resource within the Proposed Development site, and has
incorporated appropriate provision for the preservation by record of AA1 and
archaeological monitoring of the remaining site within the revised EIAR and
construction environmental management documentation. RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
2.4 Further Information Request Point 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.
Response
This response should be read in conjunction with Chapter 15 of the EIAR
(Volume II) together with Appendix 15.6 (Volume III).
The concerns raised by Monaghan County Council Heritage Section have
been reviewed in detail and the assessment of the setting of the hilltop
enclosure RMP MO022-008 has been revisited as part of the Further
Information response.
The setting of the monument was also discussed during consultation with the
National Monuments Service on the 20th of March 2026. During that
consultation, the predicted degree of effect identified in the Cultural Heritage
assessment was discussed and NMS Senior Archaeologist Hugh Carey
indicated agreement with the assessment of the effect as presented in the
EIAR (i.e. moderate indirect negative impact).
The updated Cultural Heritage assessment has been undertaken in
accordance with the approach and definitions of significance contained in the RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
EPA Guidelines on the Information to be Contained in Environmental Impact
Assessment Reports, together with relevant best-practice guidance
concerning the assessment of effects on the setting of heritage assets.
The assessment recognises that the Proposed Development will introduce a
substantial new built form into the landscape and that it will alter and restrict
views to the north-east from the hilltop enclosure. This change has not been
understated. The resulting effect on the visual amenity and setting of RMP
MO022-008 is assessed as a moderate negative residual effect. The specialist
assessment does not, however, support characterising the effect as a
substantial or profound adverse impact on the monument or its setting.
The reasons for this conclusion are set out in detail in revised Chapter 15 –
Cultural Heritage. In particular, the identified visual change affects one
directional component of what is otherwise a broad and panoramic setting.
The Proposed Development will not result in any direct physical effect on the
monument, will not alter its archaeological fabric or principal characteristics,
and will not prevent its continued appreciation or understanding within the
wider landscape. The greater part of its wider landscape setting will remain
unchanged. The final Cultural Heritage assessment accordingly predicts a
moderate negative residual effect on its setting.
Importantly, the assessment does not rely on landscaping or earthen berms
to reduce the effect below this level. The proposed landscape treatment will
assist in the longer-term integration of the development into the receiving
landscape, but the Cultural Heritage assessment conservatively retains the
predicted residual effect on RMP MO022-008 at moderate negative
notwithstanding that planting. This directly addresses the concern of the
Heritage Section that planting or berms should not be relied upon as the
basis for avoiding an adverse setting effect.
With regard to the specific concern raised regarding intervisibility between
RMP MO022-008 and the stone row at Drumgole, RMP MO017-068,
additional field assessment and photographic analysis have been
undertaken. The stone row is located approximately 1.5 km north-east of the
hilltop enclosure. The further assessment confirms that there is currently no
intervisibility between the two monuments, due principally to intervening
topography and field boundaries. There is also no archaeological evidence to
demonstrate that the two monuments are contemporary or that an
intervisible relationship between them formed part of their cultural
significance.
The additional assessment further demonstrates that the existing field
boundary adjoining the stone row substantially limits views towards the
Proposed Development, including under winter conditions, when trees are
not in leaf. The Proposed Development will therefore not interrupt an RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
existing visual relationship between RMP MO022-008 and RMP MO017-068,
as no such visual relationship presently exists. Please refer to the
Photomontage Book, specifically CHVP2.
Having regard to the above, it is submitted that the Proposed Development
is consistent with Policy PMP 1 of the Monaghan County Development Plan
2025–2031. The development has been assessed having specific regard to
the significance and setting of RMP MO022-008; there will be no direct
physical impact on the monument; the identified effect is limited to a
directional change within its wider setting; established relationships with
other recorded monuments will not be interrupted; and the residual effect
has been assessed as moderate negative rather than the substantial effect
suggested in the Heritage Section submission.
Accordingly, while a change to the north-eastern aspect of the monument’s
setting is acknowledged, the detailed assessment demonstrates that the
integrity, legibility and principal archaeological characteristics of RMP
MO022-008 will be retained and that the Proposed Development does not
give rise to an effect of such magnitude as would warrant resistance under
Policy PMP 1.
2.5 Further Information Request Point 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. RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Response
This response should be read in conjunction with Chapter 15 of the EIAR
(Volume II).
The concerns raised by Monaghan County Council Heritage Section in
relation to the former New Park estate have been reviewed and the Cultural
Heritage assessment has been expanded as part of the Further Information
response to provide a more detailed evaluation of the surviving estate, its
historic development, designed landscape, views and setting.
New Park estate is included in the NIAH Garden Survey. Neither New Park
House nor any other element of the former estate is included in the NIAH
Building Survey or the Record of Protected Structures. The historic mapping
and surviving landscape features have nevertheless been assessed in detail
having regard to Policies DLP 1 and DLP 2 of the Monaghan County
Development Plan 2025–2031.
The assessment confirms that relatively little of the designed landscape
depicted on the First Edition six-inch Ordnance Survey map of 1834 now
survives. The surviving elements relevant to the historic setting of New Park
House comprise the former parkland to the south/front of the house,
together with the associated southward view, and a curved line of trees
associated with the former estate layout. The trees and observatory formerly
located within the southern parkland were removed during the nineteenth
century, although the broad form of the open area in front of the house
remains.
Importantly, the Proposed Development will not affect the surviving designed
view from New Park House. The house was orientated southwards towards
the former parkland, and the historic designed setting of the house is focused
in that direction. The Proposed Development is located to the north, to the
rear of the house, and will not be visible from New Park House.
The lands to the north of the house, within which the Proposed Development
is located, are not identified as parkland on the historic mapping. They
historically formed part of the agricultural or working lands to the rear of the
estate rather than part of a designed vista. The nineteenth-century courtyard
buildings and associated semi-circular tree copse also served to visually
separate the working portion of the estate from the house and parkland.
Those northern lands are now in agricultural use and are no longer legible as
part of a nineteenth-century designed landscape. No estate boundary walls,
specimen trees or other designed landscape features survive within the area
proposed for development. Modern agricultural buildings have also been
introduced within the former estate immediately to the rear of New Park
House. The updated Cultural Heritage assessment therefore concludes that
this part of the former estate has a low sensitivity and does not materially
contribute to the significance of New Park House or its principal historic
setting.
Having regard to these findings, the detailed specialist assessment does not
support the characterisation of the effect as a “very significant impact” on New RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Park estate. Applying the significance methodology used in Chapter 15 of the
EIAR, the magnitude of change is assessed as medium against a receptor of
low sensitivity, resulting in a slight direct negative effect on the former estate
during the operational phase. The revised Chapter 15 confirms that this slight
negative effect remains as the residual effect.
A slight effect is acknowledged because the Proposed Development
introduces new development within land that historically fell within the wider
ownership of the estate. It does not, however, adversely affect the surviving
designed landscape features, the historic southward view from New Park
House, the appreciation of the house within that setting, or any surviving
designed vista to or from the house.
Accordingly, it is submitted that the Proposed Development is consistent with
the objectives of Policies DLP 1 and DLP 2. A detailed evaluation of the historic
house, former demesne, surviving landscape features, designed views and
vistas has been undertaken, as expressly required by DLP 2. That assessment
demonstrates that the principal historic setting and designed views
associated with New Park House will be retained and unaffected, and that
the effect on the less sensitive and substantially altered agri cultural lands
forming the rear portion of the former estate is limited to slight negative.
The assessment is set out in the revised Chapter 15 Cultural Heritage of the
EIAR, which should be read in conjunction with the response to Item 4 above
in respect of Policy PMP 1.
2.6 Further Information Request Point 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, regrading 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 RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
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.
Response
The previously proposed Soil Relocation Area has been removed from the
Proposed Development. Accordingly, no land reprofiling or associated
construction activity is now proposed on the agricultural field adjoining the
L2320.
As a consequence, the existing gated agricultural access onto the L2320 will
not be used for any construction traffic associated with the Proposed
Development. No intensification of that access is proposed, and no works are
required to facilitate development traffic at that location.
The requirements of Items 6(a) and 6(b), relating to the provision of 70 m
visibility splays and, where necessary, third-party legal agreements to
facilitate those splays, therefore no longer arise in respect of the revised
Proposed Development.
Surplus excavated soil and stone arising from construction of the Renewable
Biogas Plant will instead be removed from the site via the L2280 and R189
and thereafter transported via the appropriate regional road network to an
appropriately authorised receiving facility or facilities. The revised
construction traffic associated with this arrangement has been assessed in
the updated Chapter 6 Traffic and Transport of the EIAR.
The revised assessment confirms that the removal of the Soil Relocation Area
does not give rise to any new significant traffic or transportation effects. The
change associated with the revised soil management approach is the greater
haulage distance travelled by vehicles transporting the surplus material,
rather than a material increase in the quantity of material requiring
transport.
Accordingly, the specific road safety concern raised in Item 6 in relation to
intensification of the L2320 agricultural access has been removed from the
Proposed Development.
2.7 Further Information Request Point 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 RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
significant hedgerow removal and the extensive earth berms proposed, the
applicant is requested to submit a costed landscaping plan for the proposed
development.
Response
A Landscape Plan and Landscape Management and Maintenance Schedule,
including a detailed costing for the proposed landscape works, has been
prepared by the project landscape consultant and is submitted with this
Further Information response, see Attachment B.
The Applicant is committed to the full implementation and ongoing
maintenance of the landscape scheme. In the event of a grant of permission,
the Applicant would have no objection to a condition requiring the landscape
works to be implemented in accordance with the approved plans and
programme and, if considered necessary by the Planning Authority, to the
provision of an appropriate landscape bond or other financial security prior
to the commencement of development to secure satisfactory completion and
establishment of the works in accordance with Section 15.22.4 of the
Monaghan County Development Plan 2025–2031.
Accordingly, the requirements of this Further Information item are
considered to have been fully addressed.
2.8 Further Information Request Point 8
2.8.10 Car Parking
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.
Response
Policy CP 1 of the Monaghan County Development Plan 2025–2031 requires
car parking provision to be considered having regard to the standards set out
in Section 15.24 and Table 15.5 of the Development Plan.
The Applicant acknowledges that Table 15.5 does not prescribe a specific
parking standard for an anaerobic digestion or renewable biogas facility. The
closest general land-use category is ‘Industry’, for which a maximum
provision of 1 no. car parking space per 50 sq.m gross floor area is identified.
The direct application of a floor area based industrial parking standard to the
Proposed Development would not, however, provide an appropriate
measure of actual parking demand. The Renewable Biogas Plant is a highly RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
automated process facility in which staffing levels are low relative to the
overall building footprint. A substantial proportion of the built floor area
accommodates process equipment, feedstock reception, storage and
treatment infrastructure rather than employment-generating floorspace of
the type associated with a conventional industrial or manufacturing facility.
Parking demand is therefore determined by the number of personnel on site,
shift arrangements, visitor requirements and occasional service and
maintenance personnel rather than by gross floor area.
The Proposed Development is expected to employ approximately 30 no.
personnel operating across two shifts, with the larger shift comprising
approximately 22 no. personnel. A total of 35 no. car parking spaces is
proposed, comprising:
• 30 no. standard parking spaces;
• 2 no. accessible parking spaces; and
• 3 no. electric vehicle charging spaces.
The proposed parking provision is therefore capable of accommodating the
anticipated operational workforce, including staff present during shift
changeover, together with reasonable capacity for visitors and occasional
service and maintenance personnel attending the facility.
Importantly, the use of a demand led approach to parking provision at
renewable bioenergy is supported by experience at comparable permitted
and operational developments.
A particularly relevant comparator is the Applicant's Renewable Bioenergy
Plant at Little Island, Co. Cork. The Cork County Development Plan 2022–2028
similarly provides a maximum parking standard of 1 no. space per 50 sq.m
for light and general industry. Application of that standard to the waste
reception area alone would have indicated a maximum provision of
approximately 75 no. spaces.
The Little Island facility is likewise a highly automated renewable bioenergy
development with relatively low staffing requirements in comparison with its
overall floorspace. The planning application initially proposed 31 no. parking
spaces. In determining the application, Cork County Council specifically
required the quantum of parking to be reduced in line with the objectives of
the Cork County Development Plan.
In compliance with that requirement, the parking provision was reduced
from 31 no. spaces to 24 no. spaces, comprising:
Parking Type Originally Proposed Revised Provision
Staff parking 15 9
Accessible parking 1 1
EV parking 2 2
Motorcycle parking 2 4 RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Visitor parking 11 8
Total car parking 31 24
The Little Island example is particularly instructive in the context of the
present application. Little Island is located within an established industrial
area with a substantially greater level of surrounding employment, transport
infrastructure and potential for alternative travel modes than the rural
location of the Proposed Development. Notwithstanding that more
connected context, Cork County Council considered that the originally
proposed parking provision should be reduced and required the final
provision to be more closely aligned with the actual staffing and operational
requirements of the renewable bioenergy facility rather than with a generic
industrial floor area standard.
The Applicant does not suggest that the same numerical provision should be
applied directly to the Proposed Development at Monaghan. The rural
location of the Renewable Biogas Plant, the limited availability of public
transport and the greater likelihood of staff travelling by private car have
appropriately been considered in determining the parking provision. This is
reflected in the proposed 35 no. spaces, which represents a materially
greater level of provision than at Little Island and provides appropriate
capacity for the anticipated workforce, shift changeover, visitors and
occasional service and maintenance personnel.
The relevance of Little Island is therefore that it demonstrates, in the case of
a directly comparable renewable bioenergy facility, that gross floor area is
not an appropriate proxy for parking demand. The appropriate approach is
to assess parking having regard to the actual operational characteristics of
the facility and its locational context. Applying that same principle at
Monaghan supports a higher provision than at Little Island because of the
rural location, while still demonstrating that application of the generic
industrial maximum would result in substantial and unnecessary over-
provision.
This approach is further supported by a number of other permitted and
operational anaerobic digestion, waste processing and process-led facilities:
Development Indicative
Provision
Applying Generic
Industrial
Standard
Actual /
Permitted
Parking
Provision
Little Island Renewable Bioenergy
Plant, Co. Cork
Approx. 75 spaces
based on waste
reception area
alone
24 spaces
following PA-
required
reduction RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Huntstown Renewable Bioenergy
Plant, Fingal – Reg. Ref.
FW13A/0089
Approx. 191
spaces
20 spaces
Gorteen Lower AD Facility, Nurney,
Co. Kildare – Reg. Ref. 201117
Approx. 270
spaces
11 spaces
Huntstown/Coldwinters Materials
Recovery Facility – Reg. Ref.
FW23A/0111
Approx. 200
spaces
58 spaces
Thorntons Recycling, Cappogue –
ABP Ref. 315257-22
In excess of 217
spaces
44 spaces
Waste Processing and Recovery
Facility, Cootehill, Co. Cavan – Reg.
Ref. 16136, as modified by 2460647
Approx. 70 spaces 13 staff spaces
plus 10 lorry
spaces
Of particular relevance are the operational anaerobic digestion facilities at
Huntstown and Nurney. The Huntstown Renewable Bioenergy Plant was
permitted to process approximately 90,000 tonnes of biodegradable material
per annum and is served by 20 no. car parking spaces, notwithstanding that
application of the relevant industrial floor-area standard would have
indicated approximately 191 no. spaces. Similarly, the operational anaerobic
digestion facility at Nurney, which processes approximately 48,000 tonn es
per annum, is served by 11 no. car parking spaces notwithstanding that the
applicable generic industrial standard would have indicated a substantially
greater provision.
The evidence from these comparable facilities demonstrates that gross floor
area is not an appropriate standalone basis for determining parking demand
at highly automated renewable bioenergy facilities. Parking provision has
instead appropriately been related to the actual staffing profile and
operational requirements of the particular development.
In the present case, the proposed 35 no. spaces have been determined
having regard to the anticipated workforce of approximately 30 no.
personnel across two shifts, including provision for shift changeover, visitors
and occasional service and maintenance personnel. The provision is
therefore considered appropriately calibrated to the reasonable operational
demand of the Renewable Biogas Plant.
Provision of parking substantially in excess of this level solely to approach the
generic maximum industrial standard would serve no identified operational
requirement and would result in unnecessary additional hardstanding and
land take.
Accordingly, it is submitted that the proposed parking provision is
appropriately justified having regard to the operational characteristics of the
Renewable Biogas Plant, the maximum standards contained in Table 15.5
and the evidence from comparable permitted and operational facilities. The
proposed 35 no. spaces will satisfactorily accommodate the parking demand
generated by the Proposed Development and are considered consistent with RECEIVED: 28/08/2026
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Information Request
Policy CP 1 and Section 15.24 of the Monaghan County Development Plan
2025–2031.
2.8.11 Vehicle Swept Path Assessments
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)
Response
The Planning Authority notes that the conclusions of Section 6.8.1.3 of the
EIAR are not accompanied by swept path drawings demonstrating the vehicle
movements referred to in the assessment.
Swept Path assessments for the upgraded junction of the R189/L2280 and
the development access from L2280 are shown in Trafficwise Ltd. Drawing
03208/PL02 ‘Proposed Road Improvement & Access – Swept Path
Assessment’, which shows various turning manoeuvres undertaken by a
Freight Transport Association Design Articulated Vehicle (2016)
In respect of internal circulation at the development the swept path analyses
are provided in McAdam Drawing No. 1700-P09 and McAdam Drawing No.
1701-P06 enclosed in the Engineering Services Report which accompany the
original planning submission.
Drawing No. 1700-P09 demonstrates the manoeuvrability of a 16.5m
articulated HGV throughout the internal road network, including circulation
to the north-western operational area and the various service yards located
east of the internal spine road.
Drawing No. 1701-P06 demonstrates that a 400-tonne mobile crane,
required periodically for major maintenance operations, can safely access
the north-western process area and the tank farm.
The swept path assessment design vehicles represent the largest and least
manoeuvrable vehicles expected to access the site during its operational life.
The successful accommodation of these vehicles demonstrates that the
internal road geometry, junction radii, manoeuvring areas and service yards
can accommodate all routine operational traffic associated with the
proposed development.
With regard to the Planning Authority's request concerning emergency
vehicle access, it is considered that the swept path assessments already RECEIVED: 28/08/2026
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Information Request
undertaken inherently demonstrate that a standard fire appliance can access
all operational areas of the site.
A fire tender is substantially shorter and more manoeuvrable than either a
16.5 m articulated HGV or the 400-tonne mobile crane assessed as part of
the design. Accordingly, any route capable of accommodating these larger
design vehicles is, by definition, capable of accommodating a standard long
wheelbase fire appliance. The requirements of Clause 5.4 of Technical
Guidance Document Part B (Fire Safety) 2024 are therefore inherently
satisfied by the more onerous swept path assessments already completed.
Notwithstanding the above, and in direct response to the Planning
Authority's request, a separate swept path assessment has been undertaken
using a standard long wheelbase fire appliance. This assessment is enclosed
as McAdam Drawing No. 1701_P06 & 1700_P09 within the revised
Engineering Services Report (Attachment C) and confirms that the fire
appliance can access all areas of the site requiring emergency vehicle access
without conflict. The assessment vehicle used is representative of the type
of fire appliance operated by Monaghan Fire and Civil Protection Services
from the nearest fire stations located at Ballybay, Carrigmacross,
Castleblaney, Clone and Monaghan Town.
2.8.12 EIAR clarity
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.
Response
The Planning Authority’s comment is noted.
The references to Appendix 16.1 and Appendix 16.2 in the originally
submitted Chapter 6 Traffic and Transport were incorrect appendix
references arising from a numbering error.
A revised Chapter 6 Traffic and Transport is included within the updated EIAR
submitted as part of this Further Information response. The appendix
references have been corrected, and the relevant supporting and
assessments are now identified consistently within the Chapter 6 appendix
series.
For clarity, the revised traffic appendices are numbered Appendix 6-1
onwards, and the revised Chapter 6 should be read in conjunction with those
appendices.
Accordingly, the numbering error identified by the Planning Authority has
been corrected in the revised EIAR documentation.
2.9 Further Information Request Point 9
An Taisce have commented on the proposed development and have raised several
concerns under the headings of; RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
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.
Response
The Applicant has reviewed the An Taisce submission. A detailed, response
addressing each of the matters identified above is provided at Appendix A
Response to An Taisce Submission.
In summary, the response confirms that the Renewable Biogas Plant will
process a maximum of 99,000 tonnes of feedstock per annum, comprising
poultry manure, cattle manure and agri-food organic wastes arising from the
existing agricultural and agri-food sector. The detailed response addresses
the concern regarding potential upstream agricultural intensification and
explains the basis upon which the environmental effects of the Proposed
Project have been assessed. The wider EIAR likewise confirms the overall
maximum annual feedstock throughput of 99,000 tonnes.
Potential methane leakage has been considered having regard to the design
and proposed operation of the plant. The facility incorporates enclosed gas-
handling systems, process monitoring through the SCADA system, automatic
gas detection, preventative inspection and maintenance, leak detection and
repair procedures and associated operational controls.
In relation to digestate, the Proposed Development incorporates dedicated
treatment processes to produce stable and marketable fertiliser products,
including fibre digestate, dried fertiliser/pellets and ammonium sulphate.
The response explains the regulatory framework applicable to the
subsequent use of these products and the distinction between the
development for which permission is sought and subsequent agricultural
application.
The response also addresses the suggestion that injection of renewable
biomethane into the gas network would create fossil fuel lock-in. The
Proposed Project instead provides for the production of renewable
biomethane for injection into the existing gas network, thereby enabling
renewable gas to substitute for fossil natural gas and facilitating its use
across the wider energy system.
The concern raised regarding proximity to Drumintin wetland has also been
reconsidered in the context of the revised Proposed Development. The Soil
Relocation Area which formed the basis of An Taisce's concern has been
removed from the application. In addition, the retained Renewable Biogas
Plant site and surrounding wetland environment have been subject to
specific hydrological and hydrogeological assessment as part of the Further
Information response. RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Finally, the traffic and climate implications of transporting feedstocks and
products to and from the facility have been considered within the updated
EIAR. Transport-related greenhouse gas emissions are incorporated into the
Climate assessment, while the revised Chapter 6 Traffic and Transport
provides the detailed assessment of operational HGV generation,
distribution and effects on the receiving road network. The operational
assessment forecasts an average of approximately 27 HGV loads/visits per
operating day, with an 85th percentile high value of approximately 32.
Accordingly, the matters raised by An Taisce have been considered both
individually and as part of the wider review and updating of the EIAR
undertaken in response to the Further Information request. Appendix B
should be read together with the revised EIAR and supporting technical
assessments submitted as part of this Further Information response.
2.10 Further Information Request Point 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.
Response
The Applicant has reviewed all of the third-party submissions received in
respect of the Proposed Development.
A detailed response is provided at Appendix B Response to Third-Party
Submissions. Given that a number of submissions raise the same or closely
related matters, the detailed response groups the issues thematically in
order to avoid unnecessary repetition while ensuring that all substantive
matters raised are addressed. The key matters considered include traffic and
road safety; odour; air quality and human health; noise and vibration;
landscape and visual effects; lighting; water quality, hydrology and
hydrogeology; biodiversity; archaeology and cultural heritage; site selection
and planning policy; public consultation; and activities on adjoining lands.
The response also acknowledges the supportive submissions received from
representatives of the farming, poultry and agri-food sectors and the
bioenergy sector. These submissions identify, amongst other matters, the
need for sustainable management of agricultural organic materials, nutrient-
management benefits, renewable energy generation, circular-economy
benefits and support for the rural economy.
The matters raised in the third-party submissions have not been considered
in isolation. They have been reviewed alongside the Further Information
request and the additional technical work undertaken during the Further
Information process. A number of the matters raised by third parties overlap
directly with issues addressed through the revised EIAR and supporting
assessments, including the updated traffic assessment, additional
archaeological investigation, hydrological and hydrogeological assessment, RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
revised landscape and cultural heritage assessment and the removal of the
former Soil Relocation Area.
Accordingly, Appendix B should be read together with the revised EIAR and
the additional technical documentation submitted as part of this Further
Information response.
3. Conclusion
This Further Information response represents a comprehensive
reassessment and refinement of the application undertaken following the
Request for Further Information issued by Monaghan County Council and
subsequent direct engagement with the Planning Authority and relevant
Council representatives.
The main amendment arising from that process is the removal of the
previously proposed Soil Relocation Area from the Proposed Development.
The Renewable Biogas Plant remains the development for which planning
permission is sought, while the omission of the ancillary land-reprofiling
element results in a narrower proposal with a reduced physical development
footprint. Surplus excavated soil and stone arising during construction will
instead be managed off site through appropriately authorised reuse,
recovery or disposal arrangements.
The Further Information process has also resulted in a substantial body of
additional investigation and technical assessment. This has included further
archaeological testing and definition of Archaeological Area AA1; additional
assessment of the setting of the Maghernakelly Hilltop Enclosure and the
former New Park estate; hydrological and hydrogeological assessment of the
retained Renewable Biogas Plant site and surrounding wetland environment;
further consideration of traffic, access, parking and emergency vehicle
movements; revised landscape information; and detailed responses to the
submissions received from An Taisce and the 26 no. third parties.
The EIAR has been reviewed and updated to reflect the revised proposal and
the additional information prepared through the Further Information
process. The interaction between environmental factors, which was already
considered within the individual specialist chapters, has also been brought
together within a dedicated interactions chapter. The updated assessment
does not identify any new or materially different significant environmental
effects beyond those identified and assessed in the original EIAR.
The Appropriate Assessment Screening has similarly been reviewed having
regard to the revised Proposed Project and updated technical evidence. That
review does not alter the Stage 1 conclusion that likely significant effects on
European Sites can be excluded on the basis of objective scientific RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
information and that progression to Stage 2 Appropriate Assessment is not
required.
The Applicant has therefore used the Further Information process not simply
to respond individually to the matters raised by the Planning Authority, but
to review, test and bring the planning and environmental assessment
documentation into alignment with the revised proposal. The issues
identified through the Further Information request and third-party
consultation have been examined and are addressed through the revised
EIAR, supporting technical reports, drawings and this Response Report.
To conclude, the main Renewable Biogas Plant remains the development for
which permission is sought; the ancillary Soil Relocation Area has been
removed; the technical issues raised have been examined and assessed; and
the environmental assessment and supporting application documentation
have been comprehensively reviewed and brought into alignment with the
revised proposal.
Having regard to the information now submitted, the findings of the revised
EIAR and supporting technical assessments, and the mitigation and
monitoring measures incorporated into the Proposed Development, it is
respectfully submitted that the matters raised in the Request for Further
Information have been satisfactorily addressed and that the Proposed
Development can be accommodated at this location without giving rise to
unacceptable effects on the environment, residential amenity, cultural
heritage or the safe and efficient operation of the receiving road network.
The Applicant therefore respectfully requests that Monaghan County Council
proceed to determine the application favourably.
RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Appendix A – Response to An Taisce
Submission
RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Appendix B – Response to Third-Party
Submissions
RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Attachment A – Hydrogeological Risk
Assessment
RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Attachment B – Landscape
Management & Maintenance
Schedule
RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Attachment C – Revised Engineering
Services Report
RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Attachment D – Revised
Photomontages
RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Attachment E – Revised Appropriate
Assessment Screening Report
RECEIVED: 28/08/2026
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August 2026 | Response to Further
Information Request
Attachment F – Water Protection Plan
Checklist
RECEIVED: 28/08/2026