HomeMy WebLinkAbout2660018 - F.I. Received Doc. - Response to Submissions
STR010/0001-#9436218v1
Response to RFI Question 10
Item 10 of the Request for Further Information requires the Applicant to review the 26
third-party submissions received in respect of the proposed development and to provide
a detailed and comprehensive response to each of the matters raised.
The Applicant has reviewed each submission in full and has identifled the individual
planning, environmental, technical and community matters contained within them. A
number of the submissions raise the same or closely related concerns. To avoid
unnecessary repetition and to provide a clear and coherent response, the substantive
responses below are grouped under the following principal themes:
• Traffic, transportation and road safety;
• Odour;
• Air quality and population and human health;
• Noise and vibration;
• Landscape and visual impact;
• Lighting;
• Water quality, hydrology and hydrogeology;
• Biodiversity;
• Archaeology, architectural heritage and cultural heritage;
• Site selection, location and planning policy; and
• Other matters, including public consultation and activities on adjoining lands.
The Applicant acknowledges the time and effort taken by local residents, community
representatives and other interested parties in preparing their submissions. The
concerns raised have been considered alongside the environmental assessments and
technical information submitted with the application.
References in this response to mitigation, monitoring and operational controls
summarise the measures contained in the revised EIAR and supporting application
documentation. The deflnitive mitigation and monitoring commitments are those set out
in the revised EIAR, oCEMP and associated technical documents submitted with the
Further Information response.
RECEIVED: 28/08/2026
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Supportive Submissions
A total of eight supportive submissions were received in respect of the proposed
development, comprising submissions from local farmers and agricultural contractors,
poultry growers and producer groups, poultry processing and agri-food businesses, and
the Irish Bioenergy Association (IrBEA) (bioenergy sector representative body).
These submissions identify signiflcant beneflts that the proposed scheme can deliver,
including the provision of a local and sustainable outlet for poultry manure and other
agricultural organic materials; assistance to farmers in relation to nutrient management,
manure storage and regulatory compliance; the production of renewable energy and
organic fertiliser within a circular economy model; reductions in long-distance haulage,
fuel consumption and associated carbon emissions; and the creation of direct and
indirect employment and wider economic activity within County Monaghan.
The submissions also highlight the suitability of the proposed location within an
established centre of poultry and agricultural production, the contribution of the
development to national renewable energy and climate objectives, and its potential to
support the long-term viability, competitiveness and resilience of the farming, poultry
and wider agri-food sectors in the county. The main themes raised in the supportive
submissions are reviewed below.
Agricultural Benefits
The supportive third-party submissions place particular emphasis on the beneflt that the
proposed Renewable Biogas Plant will provide to County Monaghan’s farming sector,
especially its signiflcant poultry industry. They describe the management of poultry
manure and other agricultural organic materials as an increasingly pressing issue, given
the quantities generated and the difficulty of securing suitable outlets while meeting
storage, spreading and nutrient-management requirements. The submissions therefore
regard the development as important agricultural infrastructure that will provide a local,
structured and sustainable outlet for materials already arising within the county.
A consistent point in the submissions is reference to constraints associated with on-farm
storage, closed spreading periods, land-application requirements and increasing
regulatory obligations, including under the Nitrates Directive. They also highlight the
present need to transport signiflcant quantities of poultry litter outside County
Monaghan. In their view, the facility will help farmers manage these materials more
effectively while maintaining viable, productive and environmentally responsible farm
enterprises.
The submissions also identify improved nutrient management as a major beneflt. They
support a more controlled and traceable pathway through which the nutrients in poultry
manure can be recovered and returned to productive use. As detailed in the application, RECEIVED: 28/08/2026
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the proposed biogas plant will produce renewable biomethane and stabilised, nutrient-
rich digestate that could be used by farmers in accordance with nutrient-management
plans or supplied to the horticulture sector, rather than continuing to contribute to local
nutrient-management pressures.
The submissions further point to the value that can be recovered from material currently
presenting a management challenge. The application estimates production of
approximately 76,000 tonnes per annum of sustainable fertilisers, with a nutrient value
capable of avoiding up to approximately €3 million of imported inorganic fertiliser. This
supports the submissions’ view that an indigenous supply of clean fertiliser with
quantifled nutrient values will beneflt agriculture and horticulture and improve resilience
to volatility in international fertiliser markets.
Supportive submissions also associate the project with reduced pressure from excess
manure, improved protection of soils and water, reduced nutrient emissions and a
cleaner means of managing agricultural residues as digestate fertiliser produced by
biogas plants provides better nutrient availability for crop uptake and reduced leaching
risks. Overall, the submissions present the proposal as a practical response to a speciflc
agricultural need in County Monaghan that will support the long-term resilience and
sustainable development of the poultry and wider agri-food sectors.
Circular Economy and Renewable Energy Benefits
A strong theme throughout the supportive submissions is that the development
represents a circular-economy solution rather than simply a means of disposing of
agricultural waste. The submissions support the recovery of energy, nutrient and carbon
value from poultry manure and other locally generated organic materials. This is refiected
in the proposed production of renewable biomethane, sustainable biofertiliser and
biogenic CO₂: biomethane would displace fossil-derived natural gas, digestate would
recycle nutrients as sustainable fertiliser, and biogenic CO₂ would be captured for
industrial use. The project is therefore supported for converting an existing agricultural
residue into useful products while retaining value within the economy.
Local farmers and poultry-sector interests repeatedly identify the conversion of
agricultural organic materials into renewable energy as a key project beneflt. Their
submissions describe the proposal as a responsible and sustainable solution that will
address an agricultural residue-management issue while contributing to Ireland’s
renewable-energy and climate objectives. The renewable-energy element is presented
as integral to the circular model: locally arising materials would be converted into
indigenous energy and useful by-products rather than treated solely as waste.
IrBEA’s submission places particular emphasis on the national energy context. It refers
to the National Biomethane Strategy and the target of 5.7 TWh of biomethane production
by 2030, noting that a substantial number of large-scale biogas facilities will be required. RECEIVED: 28/08/2026
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IrBEA considers projects of this nature important for reducing dependence on imported
fossil fuels, cutting emissions and decarbonising the gas network. It also highlights
biomethane’s role in difficult-to-electrify sectors such as heavy transport and industry
and its ability to complement wind and solar generation as a reliable, dispatchable
renewable-energy source.
The application quantifles the scale of the renewable-energy and climate beneflts
identifled in the submissions. The plant could produce up to 120 GWh of renewable gas
annually, stated to be sufficient for approximately 11,000 homes, and could reduce
greenhouse-gas emissions by up to approximately 42,000 tonnes of CO₂ equivalent per
annum, comparable to removing around 9,000 cars from public roads. These flgures
reinforce the submissions’ view that the development will make a meaningful
contribution to indigenous renewable-energy production and decarbonisation.
Supportive submissions also connect the circular-economy case with wider
environmental gains, including better manure management, reduced nutrient emissions
to air and water, lower transport emissions and replacement of fossil-based energy and
fertiliser inputs. The application supports those points through a facility design
incorporating sealed handling of organic materials, digestate treatment, SuDS-based
drainage, process-water reuse and measures to protect surface and groundwater. The
submissions therefore present the proposal as recovering useful energy and nutrients
while reducing the environmental pressures associated with existing manure-
management practices.
Economic Benefits
The supportive submissions place substantial emphasis on the economic beneflts that
the development would bring to County Monaghan and the wider rural economy. The
project will deliver capital investment, direct and indirect employment, local
expenditure, opportunities for farmers and agricultural businesses, and increased
demand in sectors such as haulage, contracting, maintenance and agricultural supply
chains. Several submissions regard investment of this type as important to sustaining the
economic vitality of rural communities and supporting the established farming, poultry
and agri-food sectors.
The submissions also emphasise that the project will generate wider beneflts through its
local supply-chain relationships. By creating a new outlet for agricultural materials and
demand for associated services, it is seen as capable of sustaining existing employment
and supporting future growth. IrBEA similarly highlights opportunities in feedstock
supply, logistics, plant maintenance and associated services, together with additional
economic beneflt for farmers supplying sustainable agricultural feedstocks. Its
submission stresses the value of retaining this activity and economic value within rural
areas. RECEIVED: 28/08/2026
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The Economic Impact Assessment quantifles the scale of the beneflts identifled in the
submissions. The proposed development represents an investment of approximately
€120 million. During the anticipated two -year construction period, it is estimated to
support around 100 direct jobs and up to 140 indirect jobs, with a GVA uplift of
approximately €43 million, including approximately €7 million within County Monaghan.
This will provide a signiflcant temporary stimulus for contractors, engineering and
professional services, transport, accommodation and other businesses supplying the
project.
During operation, the plant will support approximately 30 direct jobs and 75 indirect
supply-chain jobs, including employment in haulage, contracting, administration and
other services. Annual GVA uplift is estimated at approximately €23 million, of which
approximately €7 million per annum will beneflt County Monaghan, supporting the
submissions’ case for long-term employment linked to the green and bioeconomy
sectors.
The submissions’ emphasis on local economic beneflt is further supported by recurring
operational expenditure. Annual expenditure is estimated at approximately €3.5–€4.5
million, with a substantial proportion expected to be spent locally, while commercial
rates could contribute up to approximately €400,000 per annum to Monaghan County
Council. Taken together, these flgures reinforce the submissions’ view that the project
will deliver rural investment and economic activity extending beyond the plant itself
through farmers, hauliers, contractors, suppliers and service providers.
Site Location Support
A number of supportive third-party submissions speciflcally identify the proposed
location as a signiflcant advantage. They emphasise that the site lies within one of the
country’s principal poultry-producing areas and is therefore close to the agricultural
feedstocks that the facility is intended to process. In their view, locating the plant within
the main poultry-growing area makes practical and logistical sense by placing treatment
infrastructure close to the farms generating the material, reducing unnecessary transport
distances and associated emissions, and providing a locally accessible outlet for poultry
manure.
The location arguments made in the submissions align with the site-selection rationale
in the EIAR, which sought proximity to the principal poultry-manure resource together
with feasible access to the national gas transmission network. County Monaghan was
identifled because of its exceptionally high concentration of poultry production and
availability of agricultural residues, while the Maghernakelly site is approximately 3.5
km from the existing gas transmission network. These characteristics support the
submissions’ view that the site is appropriately located in relation to both its agricultural
inputs and renewable-energy output. RECEIVED: 28/08/2026
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Accordingly, the supportive submissions reinforce the conclusion that the selected site
has a strong functional relationship with the purpose of the development. It is located
where the agricultural need and feedstock resource are concentrated, can minimise
avoidable transport of poultry manure and can facilitate connection of renewable
biomethane to the national gas network. The submissions therefore support
Maghernakelly as a location particularly suited to infrastructure intended to provide a
sustainable local solution for poultry-manure management while supporting the
agricultural sector in County Monaghan.
Observations
Traffic & Transportation
The third-party submissions raise a range of concerns in relation to traffic and road safety.
The local road network is described as comprising narrow rural roads which are
considered unsuitable for sustained HGV movements, with particular concerns
regarding road width, dangerous bends, restricted visibility, junction geometry, unstable
verges and the absence of footpaths, lay-bys and other pedestrian infrastructure.
Concerns are also raised regarding the potential interaction of increased HGV traffic with
school buses and children at roadside collection points, pedestrians, cyclists, walkers,
elderly and vulnerable road users, agricultural vehicles and other local traffic. Blackkesh
Crossroads is speciflcally identifled as a school bus stopping point and a location where
road safety concerns and previous accidents have arisen.
A number of submissions question whether the projected HGV movements accurately
refiect the likely traffic generated by the Proposed Development, including by reference
to traffic levels observed at other comparable facilities, and raise concerns regarding
additional traffic associated with the removal of excavated material and the potential
diversion of vehicles onto unsuitable local side roads. Related concerns include possible
deterioration of the road network, increased noise, dust and vibration, potential damage
to underground services adjacent to the roads, including infrastructure associated with
the Drumgole Group Water Scheme, and the ability of the site to accommodate HGVs in
the event of vehicles arriving concurrently or a temporary backlog occurring.
Submissions also raise the absence, at the time of the original application, of a Traffic
and Transport Assessment, Road Safety Audit and structural assessment of proposed
haul routes, and refer to the setback requirements for development adjoining roads
contained in the Monaghan County Development Plan.
Response RECEIVED: 28/08/2026
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Observations received in relation to traffic, transportation and road safety have been
reviewed. These matters were comprehensively assessed within the EIAR and are further
addressed below.
Suitability of Local Roads
A comprehensive Traffic and Transport Assessment forms part of Chapter 6 Material
Assets: Traffic & Transport of the EIAR, which was prepared by suitably qualifled
transportation specialists in accordance with the Transport Infrastructure Ireland (TII)
Traffic and Transport Assessment Guidelines. The assessment included:
• Baseline traffic surveys, including classifled turning counts and automatic traffic
counts.
• Assessment of existing traffic conditions and road network operation.
• Forecast construction and operational traffic generation.
• Assessment of the receiving road network.
• Assessment of junction operation and vehicle swept paths.
• Identiflcation of appropriate mitigation measures and road improvement works.
The Applicant proposes speciflc improvement works to approximately 220 metres of the
L2280 between the site access and the R189. These works include widening of the
carriageway, strengthening and resurfacing where required, verge improvements,
improved visibility and associated drainage works. The R189/L2280 junction will also be
realigned and improved to accommodate the swept paths of the largest HGVs expected
to serve the development. The road and junction improvements will be completed before
the commencement of operational HGV traffic associated with the proposed
development.
Routine construction and operational HGV traffic will access the site by way of the
improved L2280 and the R189, with onward distribution principally via the R188 and R189
Regional Roads. The L2320 Drumgole/Dernamoyle Road will not form part of the
approved HGV route and its use by development-related HGV traffic will be expressly
prohibited through the Construction and Operational Traffic Management Plans.
The approved routes will be communicated to all suppliers, contractors and hauliers
through contractual routing requirements, driver instructions and route maps. Deliveries
will also be controlled through the site booking and scheduling system. Procedures
governing road closures, emergencies and any proposed temporary route diversion will
be set out in the relevant Traffic Management Plan, and development-related HGVs will
not use unapproved local roads.
The assessment forecasts an average of approximately 27 HGV vehicle visits per working
day. Each vehicle visit comprises an arrival at and subsequent departure from the site. RECEIVED: 28/08/2026
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The assessment found that forecast traffic increases are relatively modest when
considered against existing traffic volumes on the adjacent regional road network. Traffic
will be distributed throughout the day and managed through operational procedures and
delivery scheduling.
The effect of this traffic varies across the receiving road network. The forecast increases
on the R188 and R189 Regional Roads are relatively modest when considered against
existing traffic volumes. A greater percentage increase is forecast on the short section of
the L2280 between the proposed site access and the R189 because existing traffic levels
on that road are low.
It was concluded that the R188 and R189 Regional Roads are suitable principal haul
routes for the proposed development. In addition, speciflc road improvement works are
proposed along the L2280 and at the R189/L2280 junction to facilitate safe HGV access
to the site. These works over approximately 220 metres, include localised widening, verge
improvements, improved visibility to accommodate HGV swept paths. The proposed
improvements have been designed in accordance with the requirements of TII Rural Road
Link Design and Geometric Design of Junctions standards and will ensure that the
development traffic can be safely accommodated. The R189/L2280 junction will also be
realigned and improved to accommodate the swept paths of the largest HGVs expected
to serve the development. The road and junction improvements will be completed before
the commencement of operational HGV traffic associated with the proposed
development.
Subject to completion of the proposed road and junction works and implementation of
the identifled traffic-management measures, the assessment concludes that the
forecast development traffic can be accommodated without giving rise to likely
signiflcant adverse effects on the capacity or operation of the receiving road network.
Road Safety, Visibility, Junctions and Vulnerable Road Users
An independent Stage 1 Road Safety Audit has been undertaken as part of the project
design process and was submitted as part of the planning application. This Audit was
undertaken by Traffico in accordance with TII Publication GE-STY-01024 Road Safety
Audit procedures by a team of independent, qualifled Road Safety Auditors. The audit
examined visibility, junction operation, vehicle manoeuvring, traffic generation and
interaction with existing road users.
All matters raised by the audit were reviewed by the project design team and have been
incorporated in the proposed design. These include:
• The proposed widening of the L2280 to a 6.5 metre carriageway and the realignment
of the R189/L2280 junction have been conflrmed by swept-path analysis as capable
of safely accommodating the largest HGVs permitted on public roads. RECEIVED: 28/08/2026
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• The proposed junction upgrade incorporates measures to ensure that roadside
furniture, vegetation and boundary treatments do not obstruct visibility at the
R189/L2280 junction.
• Positive drainage infrastructure and channel drains are proposed to prevent surface
water discharging from the development onto the public road.
• The access geometry will be further reflned during detailed design in consultation
with Monaghan County Council while maintaining safe HGV access requirements.
The swept-path assessment demonstrates that the largest vehicles can enter and leave
the L2280 and negotiate the R189/L2280 junction within the proposed road geometry.
Any detailed design reflnements will be agreed with Monaghan County Council and will
not reduce the proposed carriageway width, visibility or vehicle-manoeuvring
requirements.
The Traffic and Transport Assessment concludes that, subject to completion of the
proposed road and junction improvements and implementation of the identifled traffic-
management measures, the forecast development traffic can be accommodated
without giving rise to likely signiflcant adverse effects on the operation of the receiving
road network.
The Stage 1 Road Safety Audit provides a separate independent review of the road-safety
implications of the proposed design. No road safety issues have been identifled that
would preclude the development. Accordingly, the independent Road Safety Audit
conflrms that the proposed development can be accommodated safely on the receiving
road network subject to the implementation of the recommended design measures, all
of which have been accepted by the Applicant and design team.
On-Site Vehicle Holding and Queue Management
The assessment separately considers the possibility of several HGVs arriving within a
short period. Based on the forecast hourly delivery proflle, approximately six HGV arrivals
may occur during the initial hour of feedstock acceptance, reducing to approximately
three or fewer arrivals per hour during the remainder of routine operations.
The proposed internal layout provides holding capacity for up to three articulated HGVs
between the site entrance and the inbound weighbridge. Where several vehicles arrive in
close succession, additional vehicles can be directed past the weighbridge and held
within the internal yard until they can be processed. Typical weighbridge processing is
expected to take approximately three to flve minutes per vehicle.
Deliveries will also be controlled through the site booking and scheduling system. These
measures are intended to ensure that arriving vehicles can be held within the site
boundary and do not queue on the L2280.
School Buses and Vulnerable Road Users RECEIVED: 28/08/2026
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The Applicant acknowledges concerns relating to school bus routes, pedestrians,
cyclists, walkers, agricultural vehicles and other vulnerable road users. However, the
assessment concluded that the forecast traffic levels are not of a magnitude that would
materially alter the character or safety of the receiving road network.
The Construction and Operational Traffic Management Plans will require development-
related HGVs to use only the approved routes. Driver induction will include route maps,
compliance with applicable speed limits, appropriate driving behaviour on rural roads
and particular care when encountering pedestrians, cyclists, school buses, agricultural
machinery and other vulnerable road users. Route deviation and unsafe driving behaviour
will be subject to investigation and corrective action.
Building Lines and Road Setbacks
A number of submissions refer to the general 18-metre building-line guideline applicable
to County Roads in rural areas under the Monaghan County Development Plan 2025–
2031.
A detailed assessment of this matter is provided in Section 8.4.9 of the Planning
Statement. That assessment considers the proposed development having regard to
Section 15.27 and Policy BLP 1 of the Development Plan, the rural context of the site, the
proposed road-improvement works, the submitted Road Safety Audit and sightline
drawings, and the design rationale set out in the Design Statement and Chapter 3 of the
EIAR.
The main process building is set back approximately 39.4 metres from the near edge of
the surfaced carriageway of the R189, exceeding the general 30 -metre guideline
applicable to Regional Roads.
Buildings addressing the L2280 and L22802 have setbacks ranging from approximately
9.4 metres to 28.9 metres. While certain ancillary and operational buildings are therefore
located within the general 18-metre guideline applicable to County Roads, Section 15.27
expresses the relevant setback distances as general guidelines rather than absolute
requirements and allows the particular circumstances of a site to be considered.
As explained in Section 8.4.9 of the Planning Statement:
• Deflned widening and improvement works are proposed along the L2280 between
the site entrance and the R189;
• The positioning of the buildings does not interfere with the visibility splays shown on
the submitted drawings;
• The proposed setbacks do not prejudice the road-safety measures identifled
through the Road Safety Audit process;
• There is no identifled policy objective or proposal to widen or strategically upgrade
the L22802; RECEIVED: 28/08/2026
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• The development is not located within an identifled urban growth corridor or
strategic development area requiring additional future road capacity; and
• The flnal layout resulted from an iterative design process balancing road and visual
amenity, infrastructure requirements, internal circulation and the operational needs
of the facility.
The planning assessment therefore concludes that the proposed development generally
complies with the purpose and intent of Section 15.27 and Policy BLP 1. Although certain
buildings are located within the general 18-metre guideline, the departures have been
speciflcally assessed and justifled and do not prejudice road safety, sightlines or the
future functioning of the adjoining public-road network.
Furthermore, the development has been demonstrated, through the Traffic and
Transport Assessment and Road Safety Audit, to provide a safe and satisfactory
relationship with the adjoining public roads.
Forecast Traffic Volumes
The operational traffic assessment forecasts an average of approximately 27 HGV vehicle
visits per 12-hour working day. Each vehicle visit comprises an arrival at and subsequent
departure from the site. However it should be noted that, as a conservative approach,
the traffic assessment considered a ‘high-value’ traffic generation rate of 32 HGV vehicle
movements per day which is the 85th percentile of the data sample. This robust scenario
captures higher than average traffic days, refiecting variability due to seasonal peaks,
operational scheduling, or exceptional daily loads. This higher value type of assessment
is recognised in industry guidelines including TII ‘Traffic and Transport Assessment
Guidelines’ (2014) and is accepted good practice as a prudent planning metric.
The reference in the assessment to approximately two HGV visits per hour relates
speciflcally to the receiving road network’s morning and evening commuter peak hours.
It is not presented as the maximum number of HGVs that may arrive during any hour of
the working day.
The assessment separately considers the hourly delivery pattern associated with the
operation of the facility. Based on operational records from the Applicants Tully Plant in
Ballymena, approximately 20% of daily deliveries typically occur during the initial hour of
feedstock acceptance. Applying this proflle to an average of 27 daily HGV visits gives an
anticipated opening-hour arrival rate of approximately six HGVs, reducing to
approximately three or fewer arrivals per hour during the remainder of routine daily
operations.
Local residents reported observing flve HGVs entering the Tully facility during a 50-minute
period on 30 December 2025. This observation is consistent with the opening-hour
delivery proflle already considered in the Traffic and Transport Assessment and does not, RECEIVED: 28/08/2026
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in itself, indicate that the forecast daily or hourly traffic volumes for the proposed
development have been underestimated.
Deliveries will be managed through a booking and scheduling system, and the proposed
internal layout provides vehicle holding capacity within the site to prevent arriving
vehicles from queueing on the public road. The forecast traffic volumes presented in the
Monaghan EIAR were not derived from theoretical assumptions alone. The assessment
was informed by detailed operational data from the Ballymena facility, which was
adjusted to take account of the differences in digestate treatment at the back end of the
AD process. This provides a robust evidence base for forecasting future traffic generation
for the Monaghan facility.
Accordingly, the Applicant considers that the projected traffic flgures are realistic,
evidence-based and representative of the likely operational characteristics of the
proposed facility.
Road Condition, Noise, Dust and Vibration
Potential effects associated with road condition, traffic noise, dust and vibration have
been considered in Chapter 6, Material Assets: Traffic and Transport, Chapter 12, Noise
and Vibration, and Chapter 13, Air Quality, of the EIAR.
The EIAR concludes that, subject to implementation of the mitigation measures already
identifled in Chapters 6, 12 and 13, development-related traffic will not give rise to likely
signiflcant adverse dust, air-quality or vibration effects. Traffic-noise effects are assessed
in detail in Chapter 12, including the greater calculated change on the short section of
the L2280 where existing traffic levels are low.
Construction Traffic, Dust and Road Cleanliness
Construction traffic will be managed through the Construction Traffic Management Plan.
The measures identifled in Chapter 6 include the use of designated haul routes,
scheduling of construction deliveries to avoid local network peak hours where possible,
and the use of wheel-wash facilities where necessary to prevent mud or debris being
deposited on the public road.
Chapter 13 identifles a range of construction dust control measures, including dust
suppression where required, management of exposed soils and stockpiles, covering of
vehicles carrying loose materials where appropriate, inspection of nearby roads and
other receptors, and cleaning where necessary. Construction dust monitoring will
include regular inspections and monthly dust-deposition monitoring. With the identifled
mitigation measures in place, the residual construction dust effect is assessed as short-
term, localised and not signiflcant.
Construction and operational traffic emissions were also screened against the
applicable TII criteria. The forecast traffic changes do not exceed the thresholds requiring RECEIVED: 28/08/2026
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a detailed traffic-emissions assessment, and Chapter 13 concludes that no signiflcant
traffic related air quality effects are predicted.
Traffic Noise
Traffic noise associated with the construction and operational phases has been assessed
in Chapter 12 using the traffic flgures provided in Chapter 6.
During construction, predicted traffic-noise changes on the surrounding regional roads
range generally from 0.0 dB to 1.3 dB and are assessed as imperceptible to slight. A larger
increase of approximately 4.6 dB is calculated on the short section of the L2280 between
the proposed access and the R189 because the existing traffic volume on that section is
low. Chapter 12 notes that there are no noise -sensitive locations along this section of
road and that the closest noise-sensitive locations are approximately 250 metres away.
The predicted traffic-noise contribution at those locations is below 45 dB LAeq, and the
resulting construction traffic-noise effect is assessed as not signiflcant to slight and short
term.
During operation, the assessment predicts a change of less than 1 dB along the majority
of the surrounding road network and an increase of approximately 1.2 dB on the R189
south of the L2280 junction. An increase of approximately 5.1 dB is calculated on the
short section of the L2280 between the proposed access and the R189, refiecting the low
existing traffic fiows on that section. The detailed assessment of operational traffic noise
and its effect at nearby noise-sensitive locations is set out in Section 12.8.2.3 and Table
12-22 of Chapter 12.
Vibration
Potential construction vibration was assessed in Chapter 12 having regard to the relevant
guidance criteria for building response and human perception. Following
implementation of the construction mitigation measures identifled in the EIAR,
construction vibration effects are assessed as not signiflcant and temporary to short
term.
The operational development does not include activities that would normally generate
signiflcant vibration. Operational vibration effects are therefore assessed in Chapter 12
as not signiflcant.
Underground Services and Water Infrastructure
The Applicant notes concern regarding potential impacts on underground services
adjacent to the site during construction, including pipework associated with the
Drumgole Group Water Scheme. RECEIVED: 28/08/2026
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Chapter 7, Material Assets: Built Services, conflrms that watermains are present along
the roads surrounding the proposed development to the north, east and west. These
watermains form part of the Drumgole Group Water Scheme.
Available service records, the topographical survey and site inspections have identifled
associated infrastructure along the local road network, including scour valves, sluice
valves, a bulk water meter, flre hydrants and service-access manholes.
As set out in Section 7.9.2 of Chapter 7, before construction commences, the works
contractor will be required to establish the location of existing underground services.
Exclusion zones will be established around identifled services where construction
activities are restricted or subject to speciflc safety procedures.
Any planned service interruptions will be coordinated and agreed in advance with the
relevant utility provider. Works in the vicinity of existing watermains or other services will
be undertaken in accordance with the requirements of the relevant service provider and
the construction-management measures identifled in the EIAR.
All construction works affecting public roads will be undertaken in accordance with the
requirements of Monaghan County Council and relevant utility providers. Existing
services will be identifled and protected during construction, and any crossings or works
in proximity to services will be carried out in accordance with agreed engineering
standards and statutory requirements.
On this basis, Chapter 7 concludes that, following implementation of the identifled
construction measures, effects on existing built-service infrastructure will be not
signiflcant and short term.
Excavated Material Movements
Traffic associated with the transport of excavated material during construction was
assessed within the EIAR and included within the construction traffic assessment.
Excavated material will no longer be deposited in the Soil Relocation area but instead will
be removed off site by suitably authorised contractors for appropriate reuse, recovery or
disposal at an appropriately authorised receiving facility or facilities. The EIAR has been
updated to refiect this.
Chapter 6, Material Assets: Traffic and Transport, has been updated to assess the traffic
associated with the off-site transport of this material. The assessment estimates that
approximately 18,600 m³ of excavated material will require removal from the site. Based
on an average load of approximately 20 m³, this is estimated to result in approximately
930 loaded outbound HGV movements / loads over the relevant earthworks period.
Vehicles transporting excavated material will access and leave the site by way of the
L2280 and the R189, with onward travel via the regional road network to the authorised
receiving location. RECEIVED: 28/08/2026
STR010/0001-#9436218v1
The earthworks traffic forms part of the construction traffic assessment presented in
Chapter 6. Traffic associated with the removal of excavated material will be managed
through the Construction Traffic Management Plan, including the use of designated
construction routes, management of vehicle arrivals and departures, and measures to
avoid vehicle queueing on the public road.
Chapter 6 concludes that construction traffic effects will be temporary to short term.
While mitigation will reduce those effects, the assessment acknowledges that traffic
effects may remain temporarily signiflcant during brief periods of relatively intensive
construction activity.
RECEIVED: 28/08/2026
STR010/0001-#9436218v1
Odour
The third-party submissions raise concerns regarding the potential for odour emissions
associated with the handling and processing of manure, slurry, digestate and other
organic materials at the Proposed Development.
Submissions refer to reported or observed odour issues at the Applicant’s existing facility
at Tully and question the reliability of statements that the proposed facility would not give
rise to odour problems.
Concerns are also expressed regarding the potential effect of odour on nearby residential
properties, including gardens, outdoor activities and the general enjoyment of residential
amenity, having regard in particular to the proximity of nearby dwellings and prevailing
wind conditions.
Some submissions further contend that the application does not demonstrate the
presence of enforceable measures capable of completely preventing odour emissions
from occurring.
Response
The Applicant has reviewed submissions regarding potential odour emissions from the
plant. Management of air emissions and potential odour is of critical importance to
Stream and is a key aspect in the design of the proposed Monaghan plant.
Potential operational odour effects were assessed in Chapter 13, Air Quality, of the EIAR.
The assessment was prepared by AWN Consulting in accordance with relevant guidance,
including the EPA Odour Emissions Guidance Note (AG9).
The assessment considered the proposed odour emission sources, the location and
height of the emission points, surrounding buildings, nearby sensitive residential
receptors and meteorological conditions. The modelling was undertaken using flve
meteorological years and assessed the maximum predicted odour concentration at the
worst case sensitive residential receptor.
The modelling predicts 98th-percentile hourly mean odour concentrations of between
0.9 and 1.0 OUE/m³ at the worst-case sensitive receptor, compared with the relevant
guideline value of 1.5 OUE/m³. The highest predicted result is therefore approximately
68% of the guideline value. Chapter 13 consequently assesses the operational odour
effect as direct, negative, permanent and slight, which is not signiflcant.
Stream has extensive experience in air and odour containment and our similar facility in
Northern Ireland has an excellent compliance record with the Northern Ireland
Environment Agency (NIEA) and is widely considered to be the standard bearer for
environmental containment and performance in the sector. RECEIVED: 28/08/2026
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The experience from the commissioning and successful operation of that plant affords a
high level of knowledge and expertise with regard to management of air emissions and
odour containment. This expertise will be applied to the proposed Monaghan plant,
which will be a state-of-the-art development utilising best available technologies and
operating systems.
Odour Containment & Design
Odour control has been incorporated into the design of the proposed development. The
measures include:
• Delivery of feedstock in covered or sealed HGVs;
• Unloading and handling of feedstock within the enclosed main process building – no
handling or storage of feedstock or any organic material outdoors;
• Undertaking feedstock and digestate-processing activities within enclosed
buildings;
• Ventilation and extraction system will create negative pressure within the building
thereby prevent release of potential odour;
• Provision of fast-acting roller-shutter doors to limit fugitive emissions from building
entry points;
• Containment of external process stages within sealed pipes and tanks; and
• Treatment of extracted air through the proposed multi-stage odour-control system
before discharge through 40m tall odour-control stack.
The design of the plant incorporates a robust multi-stage odour control system that has
been tailored to cater for the input material and the size of the plant. This system utilises
technology that is well established and proven at a wide range of industrial facilities
worldwide (including the Stream Tully Biogas Plant) and will be continuously monitored
to ensure optimal performance.
The proposed odour-control system comprises three stages:
1. Scrubber treatment;
2. Biofllter treatment; and
3. Carbon treatment as a flnal polishing stage.
Following treatment, the air will be discharged through the proposed 40m odour-control
stack. The system will be monitored through the site’s Supervisory Control and Data
Acquisition (SCADA) system and will include alarms to identify deviations in
performance.
The air-dispersion modelling conservatively assumes continuous operation of the odour-
control emission source for 24 hours per day and 365 days per year. The assessment RECEIVED: 28/08/2026
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therefore considers a continuous operational scenario rather than relying only on limited
delivery or processing periods.
End-products from the process, including digestate, will also be stored within enclosed
buildings prior to being exported from site to markets with a demand for the valuable
nutrients they contain.
In summary, detailed odour assessment and modelling completed as part of the EIA for
the project concluded that predicted effects of the proposed development in terms of
odour are not signiflcant. It should be further noted that the proposed facility will be
licensed by the EPA under Industrial Emissions Regulations. This means the plant will be
required to comply with speciflc odour limits and monitoring requirements to ensure that
there is no impact to local residential amenity.
Prevailing Winds and Nearby Residences
The infiuence of wind direction and meteorological conditions is incorporated directly
into the dispersion modelling. The assessment uses meteorological data from Ballyhaise
and assesses flve separate meteorological years. Nearby residential receptors were
expressly included in the modelling, with the reported result representing the maximum
predicted concentration at the worst-case sensitive residential receptor.
The assessment therefore takes account of the relationship between the proposed
emission sources, prevailing meteorological conditions and nearby homes rather than
assuming that odour will disperse uniformly in all directions.
Regulation and Enforceability
The proposed development will require an Industrial Emissions Licence from the EPA
before operation. The licence will regulate process emissions and will include applicable
monitoring, compliance, reporting and incident-response requirements.
The EPA licensing process is separate from the planning process, and the precise licence
conditions will be determined by the EPA. The Applicant will be required to operate the
facility in accordance with both the planning permission and the conditions of the
Industrial Emissions Licence.
The EIAR demonstrates that the proposed containment, extraction and treatment
systems have been incorporated into the design and that the predicted odour
concentrations at sensitive residential receptors are below the applicable guideline
value. On that basis, the predicted operational odour effect is assessed as slight and not
signiflcant in EIA terms.
Comments Relating to Tully Biogas Plant RECEIVED: 28/08/2026
STR010/0001-#9436218v1
A number of submissions refer to reported odour observations in the vicinity of the
Applicant’s existing Tully Biogas Plant in Ballymena. The Applicant refutes these
comments.
While it is acknowledged that technical issues arose with the odour control system at the
Tully Plant when it was flrst commissioned in 2017, corrective measures were
subsequently implemented and the plant has since operated with an excellent
compliance record under its Northern Ireland Environment Agency (NIEA) Pollution
Prevention and Control Permit, including in relation to the applicable odour-management
requirements. This was explained to residents at the public consultation event in
December 2025.
The comment suggesting that Stream employ someone to monitor odours in the local
areas only because there are odours from the plant is entirely misleading. It is a
requirement of the NIEA permit and Odour Management Plan to carry out regular odour
monitoring around the site boundary, which is the purpose of this activity. Furthermore,
the Applicant is proactive in informing local residents of proposed maintenance activities
at the plant, which is considered good practice and encouraged by the NIEA.
The operational experience gained at Tully, including the experience arising during
commissioning, has informed the design and proposed management of the Monaghan
facility. However, the environmental acceptability of the proposed Monaghan
development has been assessed on the basis of its own site-speciflc circumstances
rather than solely by reference to the operating history of the Tully facility.
Chapter 13 of the EIAR assesses the proposed Monaghan facility having regard to its
speciflc process design, odour-containment and treatment systems, stack
characteristics, local meteorological conditions and nearby sensitive residential
receptors. That assessment concludes that the predicted operational odour effect will
not be signiflcant. The proposed development will also require an Industrial Emissions
Licence from the EPA, under which its emissions, monitoring, reporting and compliance
obligations will be regulated.
RECEIVED: 28/08/2026
STR010/0001-#9436218v1
Air Quality and Public Health
The third-party submissions raise concerns regarding potential effects on air quality,
human health and residential amenity arising from the Proposed Development. Matters
identifled include emissions from the process and associated stacks, methane,
ammonia, sulphur compounds and nitrogen oxides, emissions from generators and HGV
traffic, as well as dust, insects, flre and explosion risk and the operation of the gas fiare.
Concerns are also expressed regarding the proximity of the Proposed Development to
nearby homes and the potential for these effects, individually and in combination, to
adversely affect family life, outdoor recreation, the use and enjoyment of homes and
gardens, rural tranquillity, residents’ wellbeing and property values. Particular concern is
expressed in relation to potentially vulnerable members of the local community,
including children, elderly residents and people with serious medical conditions or
disabilities.
Some submissions contend that the combined environmental and operational effects of
the Proposed Development could result in an unacceptable loss of residential amenity.
Response
The potential effects of the proposed development on air quality, human health and
residential amenity have been comprehensively assessed within the EIAR. The
assessments conclude that, following implementation of the embedded design
measures and mitigation identifled in the EIAR, the proposed development will not give
rise to signiflcant adverse effects on air quality, human health or residential amenity.
These conclusions are based on recognised assessment methodologies, detailed
atmospheric dispersion modelling and consideration of all relevant sensitive receptors.
The proposed plant will be a state-of-the-art development utilising best available
technologies and operating systems and will be managed in strict accordance with
health, safety and environmental legislative requirements. It will also be stringently
regulated by Monaghan County Council, the EPA, the Department of Agriculture, Food
and the Marine (DAFM) and the Health and Safety Authority (HSA), with standards and
controls applied by the authorities that are designed to protect air quality and human
health.
Matters associated with air quality and public health were fully addressed throughout
the EIAR, including in the following chapters:
• Chapter 4 – Population and Human Health;
• Chapter 6 – Material Assets: Traffic and Transport;
• Chapter 13 – Air Quality; and
• Chapter 16 – Major Accidents and Disasters RECEIVED: 28/08/2026
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The Population and Human Health Chapter speciflcally considers the combined
infiuence of these environmental factors on nearby residents rather than considering
each topic in isolation.
Air Emissions and Human Health
Observations submitted raise concerns regarding potential emissions from the
proposed facility, including methane, ammonia, sulphur compounds, nitrogen oxides,
combustion emissions, HGV emissions and dust. These matters were comprehensively
assessed within the Air Quality Chapter of the EIAR using recognised atmospheric
dispersion modelling techniques and accepted assessment methodologies.
Several observations refer to methane emissions. Biomethane is the principal product
of the process, and the plant has been speciflcally designed to maximise gas capture
and utilisation. The facility will operate under a comprehensive preventative
maintenance and inspection programme speciflcally designed to minimise the
potential for fugitive methane emissions. Further details on inspection procedures are
provided in response to RFI Question 9 (An Taisce response). The assessment
considered all relevant operational emission sources associated with the proposed
development, including combustion plant, process emissions, traffic emissions and
construction dust.
Atmospheric dispersion modelling speciflcally considers stack location, height,
emission characteristics, local meteorological conditions and receptor locations in
order to predict pollutant concentrations at nearby residential properties. Modelling
was undertaken using recognised regulatory methodology and incorporated the
proposed stack location and height, emission characteristics, local meteorological
conditions and nearby sensitive receptors. The modelling demonstrates that predicted
ground-level concentrations of all relevant pollutants, including nitrogen oxides (NOx),
sulphur dioxide (SO₂), ammonia (NH₃) and particulate matter, comply with the
applicable ambient air quality standards and health-based guideline values at all
residential receptors. Accordingly, no signiflcant adverse effects on human health are
predicted.
Furthermore, the proposed development will operate under an EPA Industrial Emissions
Licence. As part of that licensing process, air emissions will be independently regulated
by the EPA through legally enforceable emission limit values, monitoring requirements
and compliance obligations throughout the operational life of the facility.
Dust
Concerns have been raised regarding dust emissions during construction. Potential
temporary dust emissions associated with earthworks and construction activities will
be controlled through a range of standard mitigation measures, including: RECEIVED: 28/08/2026
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• Dust suppression using water where necessary;
• Wheel washing facilities;
• Management of exposed soils;
• Covering of loaded vehicles where appropriate;
• Regular road cleaning where required; and
• Implementation of a Construction Environmental Management Plan.
Taking account of the short-term nature of the construction works and the
implementation of these measures, the EIAR concludes that signiflcant adverse dust
impacts at nearby residential properties are not predicted.
Construction of the associated gas grid connection will be undertaken as a rolling linear
operation within the public road corridor, meaning that dust-generating activities will
only occur over short sections of the route at any one time before progressing.
Consequently, any potential dust effects associated with the pipeline works will be
localised and temporary.
Vehicle Emissions
Observations have also been raised regarding emissions associated with HGV traffic.
Traffic emissions were considered within the Air Quality Assessment using the forecast
traffic generation presented in the Traffic and Transport Assessment. The predicted
increase in traffic associated with the proposed development is relatively modest in the
context of existing traffic volumes on the receiving road network. Consequently,
predicted changes in pollutant concentrations at nearby residential receptors are
negligible and comply with the relevant ambient air quality standards and health-based
assessment criteria.
Accordingly, the Proposed Development is not predicted to give rise to signiflcant
adverse effects on local air quality or human health as a result of traffic-related
emissions.
Fire, Explosion and Major Accident Risk
Some submissions express concern regarding potential flres, explosions and other
potential industrial hazards. These matters have been speciflcally considered within
Chapter 16 of the EIAR (Major Accidents and Disasters).
The proposed development will be designed in accordance with recognised engineering
standards applicable to anaerobic digestion facilities and several robust safety systems
have been incorporated into the design of the plant including mitigation for flre and
explosion risk, meaning that the chances of this happening are extremely low.
The volumes of biogas / biomethane stored on site at any one time will be very low as
the gas will be immediately removed off site via direct injection to the gas grid. RECEIVED: 28/08/2026
STR010/0001-#9436218v1
The enclosed fiare is not part of normal plant operation. It functions solely as a safety
device during commissioning, maintenance or exceptional operational circumstances
when gas cannot be exported. Accordingly, fiare operation is expected to be infrequent
(expected maximum operational time of less than 2% of the year) and of short duration.
The facility will also be subject to ongoing regulation under applicable health and safety
legislation. The Applicant notes that the proposed development is not a Seveso
establishment and is not located within the consultation distance of any Upper or
Lower Tier Seveso facility.
The Major Accidents and Disasters assessment concludes that the proposed plant
incorporates multiple engineered and operational safeguards including automatic
shutdown systems, SCADA monitoring, gas detection, pressure relief systems, bunded
storage, emergency response procedures and flre protection infrastructure. The plant
will operate in accordance with Best Available Techniques (BAT) and Industrial
Emissions Directive requirements. The assessment concludes that while the possibility
of a major accident can never be entirely eliminated, the likelihood of such an event is
very low and signiflcant off-site consequences are not predicted.
Residential Amenity
Several submissions refer to potential impacts to residential amenity from the proposed
development.
The Population and Human Health Chapter speciflcally considers these matters by
reviewing the combined effects of air quality, odour, noise, traffic, visual impact and
other environmental factors on nearby residents.
The assessment identifles the principal nearby sensitive receptors and conflrms that
the surrounding area comprises a dispersed rural population with relatively few
dwellings in close proximity to the site. Within 500 metres of the site there are 14
dwellings, with the nearest dwellings located to the south and south-east being
associated with the landholding for which consent has been provided.
Observations speciflcally refer to potentially vulnerable members of the community,
including children, elderly residents and persons with disabilities or underlying medical
conditions.
The Population and Human Health Chapter speciflcally considers the demographic
proflle of the local population, including age proflle, health status, deprivation and
disability, in accordance with recognised Health Impact Assessment guidance.
Particular concern has been expressed regarding potentially vulnerable members of the
community, including children, older persons and those with existing medical
conditions. These groups were considered within the Population and Human Health
assessment through the identiflcation of sensitive receptors and review of the local RECEIVED: 28/08/2026
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demographic proflle. As the specialist environmental assessments conclude that no
signiflcant residual effects are predicted, no signiflcant adverse effects on these
population groups are anticipated.
Following assessment of the available demographic and health data, the surrounding
population is assessed as having an overall low to medium sensitivity to environmental
change. Importantly, this sensitivity assessment is combined with the conclusions of
the specialist environmental assessments contained within the EIAR.
Residential amenity has been assessed by considering the combined effects of the
proposed development, including air quality, odour, noise, traffic, visual effects and
lighting. This integrated assessment concludes that, following implementation of the
embedded mitigation measures, the proposed development will not result in signiflcant
adverse effects on the amenity of nearby residents or on human health.
A number of submissions refer to potential impacts on property values. Property values
are not an environmental factor requiring assessment under the Environmental Impact
Assessment Directive and therefore do not form part of the EIAR. The assessment
instead considers the potential environmental effects of the proposed development on
human health and residential amenity.
RECEIVED: 28/08/2026
STR010/0001-#9436218v1
Noise & Vibration Impact
The third-party submissions raise concerns regarding potential noise and vibration
effects arising from the operation of the Proposed Development, including noise from
plant and machinery, pumps, generators and HGV movements, with particular concern
expressed in relation to early morning and nighttime activity.
Speciflc reference is also made to the possible continuous operation of a 2 MW
generator.
Submissions contend that these sources of noise and vibration could be incompatible
with the existing quiet rural character of the area and could adversely affect nearby
residential properties, residents’ quality of life and the enjoyment of their homes.
Response
The Applicant has considered submissions relating to noise and vibration. The
proposed development has been subject to a detailed Noise and Vibration Assessment
undertaken by suitably qualifled specialists (AWN) in accordance with recognised
national and international guidance, including EPA Guidance Note for Noise (NG4), BS
4142, BS 8233, ISO 1996 and the Institute of Environmental Management and
Assessment (IEMA) Guidelines. The assessment considered all signiflcant construction
and operational noise sources associated with the proposed facility, including
mechanical plant, vehicle activity, CHP engines, process equipment and ancillary
infrastructure, and the assessment flndings are outlined in Chapter 12 of the EIAR.
The proposed development incorporates a range of noise control measures including:
• Location of principal plant and equipment within purpose-designed buildings and
structures.
• Selection of low-noise equipment where practicable.
• Acoustic treatment of speciflc items of plant where required.
• Regular maintenance of mechanical equipment to ensure continued efficient
operation.
• Site management procedures to minimise unnecessary noise generation.
Construction activities will generally be undertaken during normal working hours, with
any limited out-of-hours works restricted to exceptional circumstances and managed
through the Construction Environmental Management Plan.
Detailed modelling of potential noise effects was carried out, which allow the
examination of predicted operational noise levels at nearby noise-sensitive receptors,
including existing residential houses in the vicinity of the site. Although the process will
operate on a continuous basis, the noise assessment speciflcally assessed daytime,
evening and night-time operational scenarios. RECEIVED: 28/08/2026
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The assessment concluded that, with the incorporation of the proposed mitigation
measures and plant speciflcation requirements, the facility can operate in compliance
with the applicable noise criteria and without giving rise to signiflcant adverse noise
effects at nearby residential properties.
The assessment therefore explicitly considered the principal continuous plant
associated with the facility and demonstrated that, with the proposed mitigation and
plant speciflcation, operational noise levels will comply with the applicable noise
criteria at nearby residential receptors.
Traffic noise was also assessed as part of the EIAR. The operational traffic assessment
considered development-related vehicle movements on the surrounding road network
and assessed the signiflcance of any changes in traffic noise levels. The assessment
concluded that the proposed traffic generation would not result in signiflcant adverse
traffic noise effects.
The assessment recognised that the receiving environment is rural and that nearby
dwellings represent noise-sensitive receptors. Baseline monitoring was undertaken to
characterise the existing acoustic environment, and operational noise limits were
derived accordingly.
The assessment demonstrates that construction and operational noise from the facility
will not result in unacceptable impacts on residential amenity.
In terms of potential vibration, the proposed development does not involve blasting,
quarrying, piling, rock breaking or other activities typically associated with signiflcant
vibration generation. Operational activities consist primarily of enclosed industrial
processes and normal vehicle movements. Accordingly, signiflcant operational
vibration impacts are not anticipated.
Temporary construction vibration may arise from the use of conventional construction
plant and equipment during site preparation and building works. Such effects will be
temporary, localised and managed in accordance with recognised standards, including
BS 5228 and BS 7385, through the implementation of the Construction Environmental
Management Plan. The EIAR concludes that signiflcant vibration effects are not
anticipated. In conclusion, the detailed noise modelling and assessment work
completed demonstrates that the proposed development can operate in compliance
with the applicable noise criteria and will not give rise to signiflcant adverse noise or
vibration effects at nearby residential properties. As with odour, the plant will be
subject to regulation under the EPA Industrial Emissions licensing regime, which will
impose operational environmental controls, including noise emission requirements,
providing ongoing environmental oversight throughout the lifetime of the facility.
RECEIVED: 28/08/2026
STR010/0001-#9436218v1
Landscape and Visual
The third-party submissions raise concerns regarding the potential landscape and visual
effects of the Proposed Development. Submissions refer to the extent of excavation
required and contend that the works would substantially alter the existing drumlin
landform and natural topography, including through the removal of trees and hedgerows,
with resulting irreversible effects on the rural landscape and scenic views.
Concerns are also expressed that the elevated position of the site would increase the
visibility of the development and that the scale and form of the proposed tanks, buildings
and chimney would be out of character with the surrounding rural landscape and
established residential community.
Reference is made to the site's location within a sensitive ribbed moraine landscape and
to the potential implications for the cultural and scenic value of the wider area, including
Dartry Forest, Bellamont House, the Dawson Monument, the Tyrone Guthrie Centre and
the area's tourism potential.
A number of submissions also question the effectiveness of the proposed landscape
planting in screening the development and raise concerns regarding the
representativeness of the submitted photomontages, including the seasonal conditions
in which they were prepared, the absence of sufficiently close viewpoints and the
representation of views from Blackkesh Crossroads.
Response
The Proposed Development is intrinsically linked to the surrounding agricultural
landscape through its function of processing agricultural and agri-food feedstocks into
renewable biomethane, sustainable fertiliser products and recoverable biogenic carbon
dioxide. While industrial in appearance, the facility is directly associated with the
agricultural economy that characterises the receiving landscape.
The Applicant has carefully considered the observations received in relation to
landscape and visual impact. The potential for landscape and visual impact from the
proposed development was comprehensively assessed in Chapter 5 of the EIAR, which
was prepared by Macro Works in accordance with the Guidelines for Landscape and
Visual Impact Assessment (GLVIA3).
Character of the Proposed Development
The proposed development includes process buildings, tanks and associated
infrastructure which have been designed to meet the operational requirements of a
modern renewable biomethane facility. The siting, layout, flnished levels and landscape
proposals have been developed to minimise visual prominence and integrate the facility
into the surrounding landscape.. RECEIVED: 28/08/2026
STR010/0001-#9436218v1
However, the Landscape and Visual Impact Assessment (LVIA) completed for the
development notes that the surrounding landscape is already characterised as a
productive working rural landscape containing agriculture, commercial activity, forestry,
regional roads and existing industrial and agricultural development. Existing industrial
facilities, including the Carleton Cake Factory and the Abbott Ireland complex, form
part of the wider landscape context.
The LVIA concludes that while the development represents a noticeable change within
the immediate landscape, it relates directly to the agricultural economy and does not
fundamentally alter the productive rural character of the wider landscape. The scale of
the wider drumlin landscape assists in assimilating the development into its
surroundings.
Alteration of Topography and the Drumlin Landscape
Some submissions express concern that the proposed development will substantially
alter the existing drumlin landform through excavation and earthworks.
The Applicant acknowledges that excavation and regrading are required to facilitate the
proposed development. These earthworks have been deliberately incorporated into the
design in order to partially recess elements of the development into the existing
landform, thereby reducing the overall visual proflle of the buildings and tanks.
The LVIA completed recognises that the site is located within the wider drumlin
landscape. The assessment speciflcally assesses this landscape context and
concludes that the landscape is an actively managed agricultural landscape which has
evolved through long-standing farming, forestry and associated rural enterprise. While it
possesses local landscape character, it is not subject to any national or county
landscape designation. The overall landscape sensitivity of the site and surrounding
area is assessed as Medium, refiecting the existing agricultural, forestry and
commercial land uses that already infiuence the character of the area.
Submissions refer to the geological character of the wider drumlin/ribbed moraine
landscape. The LVIA recognises this broader landscape context in assessing landscape
character and visual effects. While localised earthworks are required within the
application site, these are conflned to the site itself and do not alter the wider drumlin
landform or geological landscape character of the surrounding area.
In addition, the surrounding drumlin topography is a signiflcant factor in reducing
visibility of the proposed development by providing natural screening throughout much
of the surrounding landscape.
Visibility of the Project RECEIVED: 28/08/2026
STR010/0001-#9436218v1
Several submissions suggest that the elevated position of the site will result in
widespread visibility. This conclusion is not supported by the flndings of the LVIA.
A detailed Digital Surface Model (DSM) Zone of Theoretical Visibility (ZTV) analysis was
undertaken which incorporates existing topography together with hedgerows,
woodland, tree belts and buildings. The assessment demonstrates that:
• There is no theoretical visibility across most of the 3 km study area;
• There is no theoretical visibility from the principal lakes within the study area;
• There is very limited theoretical visibility from the village of Drum; and
• Visibility is primarily conflned to the immediate vicinity of the site, generally within
approximately 1 km, where views are intermittent due to the screening provided by
drumlin topography and vegetation.
The LVIA therefore concludes that the existing drumlin landform and dense hedgerow
network provide signiflcant natural screening throughout the surrounding landscape.
Photomontages and Representative Viewpoints
Observations have suggested that the photomontages were prepared during full leaf
conditions, that insufficient close-range viewpoints were selected and that Blackkesh
Crossroads was not speciflcally represented.
Photomontages are intended to illustrate representative views and are supported by
fleld survey, ZTV mapping and professional landscape assessment; they are not relied
upon in isolation.
The Applicant notes that the LVIA includes a comprehensive assessment based on a
combination of DSM visibility mapping, fleld survey, photography, photomontages and
ten representative viewpoints selected to refiect a range of receptor types, viewing
directions and distances, including local community views and views from the regional
road network.
Representative viewpoints are selected to assess the range of likely visual effects rather
than every possible viewing location. This is standard LVIA methodology in accordance
with GLVIA3 and is expressly recognised within the assessment.
Proposed Landscape Planting
Comments have questioned whether the proposed planting will provide adequate
screening. The proposed landscape scheme has been developed as an integral part of
the project design and is intended to supplement the substantial existing screening
already provided by mature hedgerows, trees and the drumlin landform.
While newly planted vegetation requires time to establish, the LVIA assessment has not
relied solely upon future planting to conclude that impacts are acceptable. The RECEIVED: 28/08/2026
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landscape proposals are therefore supplementary to the existing landscape structure
rather than being relied upon to mitigate otherwise unacceptable visual effects.
The assessment is based primarily upon the existing topography and vegetation which
already provide extensive screening across the study area. As the proposed planting
matures, the level of visual integration and screening will further improve over time.
Removal of Trees and Hedgerows
The Applicant acknowledges that limited sections of existing hedgerow will require
removal to facilitate the development. However, the proposed design seeks to retain
the majority of the existing boundary vegetation wherever practicable. During
construction, retained trees and hedgerows will be protected in accordance with BS
5837:2012 "Trees in Relation to Design, Demolition and Construction".
The landscape proposals also include substantial new structural planting designed to
reinforce existing fleld boundaries, strengthen landscape integration and provide
additional long-term screening. As this planting matures, the effectiveness of screening
will increase over time.
Tourism and Scenic Amenity
Some submissions suggest that the development could adversely affect tourism.
The LVIA speciflcally considers tourism, recreation and heritage assets within the study
area, including Dartrey Forest Recreation Area, Temple Loop, Dromore Lough, Inner
Lough and Annaghmakerrig Lough and concluded that the Proposed Development
would not give rise to signiflcant adverse landscape or visual effects in relation to these
receptors. The separate Cultural Heritage Assessment (Chapter 15 of the EIAR) also
concluded that no signiflcant adverse effects on cultural heritage assets or their setting
are anticipated.
The ZTV assessment demonstrates that these recreational and tourism assets generally
have no theoretical visibility of the proposed development due to the intervening
landform and vegetation. Accordingly, signiflcant adverse effects on the visual amenity
of these tourism and recreational resources are not anticipated.
In conclusion, assessment work completed in relation to potential landscape and visual
impact demonstrates that the proposed development has been carefully designed to
respond to its landscape setting through the use of inset construction, retention of
existing vegetation, additional structural planting and careful site layout.
Although some localised landscape and visual effects will occur within the immediate
vicinity of the site, these effects reduce rapidly with distance due to the natural
screening provided by the drumlin landform, mature hedgerows and woodland. The
assessment concludes that the wider landscape, designated amenity areas, tourism RECEIVED: 28/08/2026
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resources and the majority of visual receptors will experience little or no signiflcant
adverse due to intervening landform and vegetation.
Conclusion
The LVIA concludes that while the Proposed Development will introduce a noticeable
new feature within its immediate setting, the combination of site design, existing
drumlin landform, mature vegetation and proposed structural planting ensures that
landscape and visual effects are largely conflned to the immediate vicinity of the site.
Signiflcant adverse effects are not predicted for the wider landscape, designated scenic
areas, heritage assets or principal tourism receptors.
RECEIVED: 28/08/2026
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Light Spill
The third-party submissions raise concerns regarding potential light spill associated with
the 24-hour operation of the Proposed Development. Residents, including those
occupying more elevated properties, refer to the potential for direct glare and sky glow
from external and operational lighting and the consequent effects on nearby homes,
residential amenity and the existing rural dark-sky environment. Concerns are also
expressed regarding potential effects on wildlife, with particular reference to illuminated
walkways and the potential for artiflcial lighting to affect bats.
Response
The facility has been designed to ensure that light spill from the plant is kept to a
minimum and will not impact on the surrounding area. While the anaerobic digestion
process operates continuously, this does not mean that the site will be fully illuminated
throughout the night. The majority of the operational process takes place within
enclosed buildings and process tanks and does not require extensive external lighting.
External lighting will be provided only where necessary for operational safety, security
and maintenance purposes. Accordingly, the proposed development will not involve
continuous high-intensity illumination of the site.
A Light Impact Assessment has been completed as part of the survey works to assess
the potential effects of artiflcial lighting associated with the Proposed Development.
The assessment concluded that the proposed lighting design complies with the
applicable obtrusive lighting limits for a rural Environmental Zone (E2). The assessment
also conflrmed that the predicted vertical illuminance at each of the four nearest
assessed dwellings is 0.0 lux, that the calculated average surrounding light spill is only
0.32 lux, and that the nearest residential receptors are located outside this limited spill
area. The assessment further conflrmed compliance with both the applicable pre-
curfew and post-curfew lighting limits and concluded that there is no potential for
nuisance arising from obtrusive light
Where external lighting is required, it will be designed in accordance with:
• ILP Guidance Notes for the Reduction of Obtrusive Light;
• SLL LG1 Industrial Environment 2018;
• BS EN 12464 (2024);
• Environmental Zone E2 criteria; and
• CIE 150 obtrusive light limits.
The design will seek to minimise light spill beyond the site boundary and incorporated
design principles will include:
• Use of the minimum lighting levels necessary to ensure safe operation; RECEIVED: 28/08/2026
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• External lighting will be switched off from 9pm in the evening and will operate on
motion sensors;
• Anti-glare luminaires, downward-directed lighting with aiming angles below 70
degrees, and lighting columns and wall-mounted flttings positioned to minimise
glare and obtrusive light beyond the site;
• Full cut-off or fiat-glass flttings to minimise upward light spill;
• Careful orientation of lighting away from nearby dwellings;
• Avoidance of unnecessary lighting of buildings or open areas; and
• Use of modern LED lighting with appropriate beam control.
The proposed development also beneflts from existing topography, retained boundary
hedgerows and proposed perimeter landscaping which will provide additional
screening. These measures will substantially reduce the potential for glare or sky glow
affecting nearby properties.
The potential effect of lighting on bat roosts was considered in Chapter 11 (Biodiversity)
of the EIAR and concluded that the site supports negligible bat activity and therefore
would not be sensitive to potential light impact. The proposed lighting design for the
site will have regard to current ecological guidance and will seek to avoid unnecessary
illumination of existing hedgerows, woodland edges and other habitats that may be
used by bats or other nocturnal fauna.
RECEIVED: 28/08/2026
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Water Pollution
The third-party submissions raise concerns regarding the potential for water pollution
arising from leaks, spills, runoff, seepage or accidental discharges associated with the
Proposed Development.
Particular reference is made to the storage and handling of slurry, digestate and other
organic materials and the potential for polluting or noxious substances to affect
groundwater, private wells, soils, agricultural land, wetlands, bogland and local
watercourses. Concerns are also expressed having regard to the proximity of the site to
bogland, wetland areas and associated drainage or water features.
Some submissions refer to reported pollution incidents at other anaerobic digestion
facilities and contend that accidental releases from the Proposed Development could
adversely affect local water quality and the wider receiving environment.
Response
Observations submitted in response to the planning application raised concern
regarding the potential for leaks, spills, run-off, seepage or accidental discharges of
digestate, slurry, organic feedstocks, fuels or other potentially polluting materials to
affect local watercourses, groundwater, private water supplies, soils, farmland and
wetland habitats.
These matters have been assessed principally in Chapter 9, Land and Soils, and
Chapter 10, Water (Hydrology and Hydrogeology), of the EIAR. Chapter 10 assesses the
potential effects of the Proposed Development on both surface water and groundwater
and identifles the measures incorporated into the project design to prevent, contain and
manage potentially polluting releases. The assessment was prepared by appropriately
qualifled hydrology and hydrogeology specialists (AWN) in accordance with relevant
EPA, TII and Institute of Geologists Ireland (IGI) guidelines and concludes that, subject
to implementation of the incorporated design and mitigation measures, the Proposed
Development will not give rise to signiflcant adverse effects on the water environment.
Construction
The assessment recognises that the short-term construction activities represent the
period of greatest potential risk to surface water and groundwater. Potential sources
include sediment-laden run-off, fuels and oils, and concrete and cement products.
Chapter 10 identifles that, in the absence of mitigation, these materials could affect
surface-water quality or inflltrate the underlying soils and groundwater.
The Construction Environmental Management Plan and Soil and Surface Water
Management Plan therefore provide for a comprehensive range of water protection
measures, including: RECEIVED: 28/08/2026
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• Designated fuel and chemical storage areas located away from watercourses;
• Immediate containment and clean-up of any accidental spillages;
• Appropriate handling and removal of contaminated soils from site where necessary;
• Storage of waste oils and hydraulic fiuids within double-skinned tanks or bunded
containers;
• Sealed containment and appropriate off-site treatment of foul drainage from
temporary site facilities;
• Erosion and sediment control measures including silt traps and silt fences where
necessary;
• Controlled refuelling and concrete-management procedures; and
• Emergency spill response procedures.
The implementation and maintenance of these measures will be monitored throughout
the construction phase, including regular inspection of refuelling, concrete pouring,
sediment control and surface water management arrangements.
Operational Design
In relation to the operational phase of the plant, the proposed development has been
designed to prevent releases at source and strict operational management.
Operational areas of the site will beneflt from an engineered containment system
comprising impermeable surfaces and bunds, meaning containment will be provided
for all liquid storage areas. The anaerobic-digestion tanks are located within a bunded
tank farm, and the assessment of major accidental releases concludes that organic
material would be retained within the bunded containment area.
Therefore, in the unlikely event of a spill on the site, all materials will be contained and
reused in the process, preventing any potential impact to local watercourses or
groundwater.
Rainwater harvesting will form an integral part of the site drainage strategy, with
stormwater run-off from impermeable surfaces collected and reused within the plant
process. Under normal operating conditions, harvested rainwater will be reused on site
and based on the Applicant's experience of operating similar plants, routine discharge
of surface water is not anticipated. However, the drainage system has been
conservatively designed to accommodate periods of prolonged or exceptional rainfall.
In such circumstances, surplus treated surface water may be discharged in a controlled
manner via the engineered drainage system at a restricted fiow rate equivalent to the
existing greenfleld run-off rate. Only clean, treated surface water would be discharged,
and monitoring would be undertaken in accordance with the requirements of the EPA
Industrial Emissions Licence.
Potential Off-Site Impact RECEIVED: 28/08/2026
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Observations also outlined that the proposed development could alter local drainage
patterns and adversely affect nearby wetlands, and public water supplies. It is noted
that the Soil Relocation Area is no longer part of the proposed development and a
hydrological and hydrogeological assessment prepared by Hydro Environmental
Services submitted as part the RFI response concluded that there is no hydrogeological
linkage between the proposed biogas plant site and local water receptors that would
alter the hydrological balance of Drumintin Wetland or any other surrounding wetland
feature.
It further concluded that the Proposed Development would not result in deterioration of
any Water Framework Directive quality element or compromise the achievement of
Water Framework Directive objectives.
Reports of incidents at other anaerobic-digestion facilities do not demonstrate that
comparable effects would occur at the Proposed Development. The environmental
effects of this project have been assessed having regard to its particular location,
drainage design, process arrangements, containment infrastructure and proposed
operating controls.
In summary, the proposed development has been designed to incorporate modern
containment systems, enclosed processing, sealed drainage infrastructure,
comprehensive quality assurance procedures and multiple environmental protection
measures. Therefore, while potential accidental releases have been identifled and
assessed as credible risks, the Proposed Development incorporates multiple levels of
prevention, containment, drainage control, water treatment and monitoring. On that
basis, the EIAR concludes that no signiflcant adverse effects on surrounding surface
waters, groundwater, water supplies or associated wetland receptors are predicted.
Furthermore, the facility will operate under an EPA Industrial Emissions Licence, which
will regulate all aspects of environmental performance, including water protection,
storage systems, inspections, monitoring and reporting.
RECEIVED: 28/08/2026
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Biodiversity
The third-party submissions raise concerns regarding potential effects on biodiversity
arising from the Proposed Development. Species speciflcally identifled include bats, red
squirrels, otters, badgers, hedgehogs, frogs, smooth newts, common lizards and nesting
birds. Concerns are expressed regarding habitat loss and fragmentation associated with
hedgerow removal, vegetation clearance, drainage and changes in ground levels,
together with the potential for runoff and other construction or operational effects to
affect nearby habitats. Particular reference is made to bogland adjoining the L2320,
which is described in submissions as an important frog-spawning habitat, and to the
ecological and landscape value of existing hedgerows, including those along the L2280,
as habitat corridors. A number of submissions question whether the ecological
assessment has adequately considered the combined effects of lighting, noise, traffic,
vegetation removal and changes to habitat connectivity. Speciflc concerns are also
raised regarding the timing and adequacy of bat surveys, the assessment of red squirrel,
the extent of proposed hedgerow removal and whether replacement planting would
adequately compensate for the ecological function and maturity of existing hedgerows.
Response
Potential effects on biodiversity from the proposed development have been
comprehensively assessed in Chapter 11 (Biodiversity) of the EIAR, prepared by Veon
Ecology in accordance with the CIEEM Guidelines for Ecological Impact Assessment in
the UK and Ireland (2024) and relevant Irish legislation and guidance. The assessment
considered the potential direct, indirect and cumulative effects of the Proposed
Development on habitats, fiora and fauna and identifled appropriate avoidance,
mitigation and enhancement measures where required.
The assessment included extensive desktop studies and appropriately timed fleld
surveys for habitats, mammals (including bats and badgers), breeding and wintering
birds, amphibians and other ecological receptors. The Biodiversity Chapter also
considered the potential infiuence of lighting, noise, air quality, traffic, drainage,
landscaping and hydrology on ecological receptors, rather than assessing biodiversity in
isolation.
The biodiversity surveys concluded that:
• No Annex I habitats or Annex II species were recorded within the site;
• No bat roosts were identifled within the site;
• No badger setts or evidence of badger activity were recorded within the
development footprint;
• No otter holts or other signiflcant evidence of otter use was identifled within the site;
• Existing habitats are predominantly improved agricultural grassland with common
hedgerows and treelines; and RECEIVED: 28/08/2026
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• The ecological value of the site is generally low to moderate at a local level.
Hedgerow Removal
In relation to hedgerow removal, the design has sought to retain existing boundary
hedgerows wherever practicable, with removal limited to those sections necessary to
facilitate the development and road improvements. Where removal is unavoidable,
replacement native planting, hedgerow reinforcement and long-term management are
proposed to maintain and strengthen ecological connectivity. It is noted that many of
the trees requiring removal are classifled as Category U under BS 5837:2012, with a
signiflcant proportion affected by ash dieback disease.
The proposed development will enhance existing biodiversity by strengthening retained
hedgerows, creating new woodland and broadleaved planting, establishing new wildlife
habitat and implementing long-term ecological management. As such, it is in line with
and supportive of the recent Hare’s Corner initiative launched by Monaghan County
Council. Consequently, while some localised habitat loss will occur, the operational
phase includes signiflcant enhancement of existing habitats.
Lighting and Other Considerations
A number of submissions suggest that the ecological assessment did not adequately
consider lighting, noise, traffic or vegetation removal. This is not correct as the
Biodiversity Chapter speciflcally identifles lighting, traffic, noise, surface water
management and landscaping as integral components of the ecological assessment
and considers their infiuence on habitats and species throughout the Zone of Infiuence.
With respect to lighting, a dedicated Light Impact Assessment informed the project
design. The lighting system incorporates anti-glare luminaires approved by the
International Dark Sky Association, minimises upward light spill and illumination of
boundary vegetation, complies with the Institution of Lighting Professionals Guidance
on Obtrusive Light, and incorporates time-clock controls to switch off unnecessary
lighting after 9pm wherever operationally practicable. The ecological assessment
concludes that, with implementation of this lighting strategy, there will be no signiflcant
residual effects on bats.
Similarly, the assessment considers construction noise, vibration, traffic and water
quality effects, together with the mitigation measures contained within the relevant
chapters of the EIAR, before determining the overall ecological effects.
Bat Surveys
It was suggested that bat surveys were undertaken outside the recognised survey
season, which is not correct. Bat surveys were undertaken during the months of July RECEIVED: 28/08/2026
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and August 2024 under suitable weather conditions and within the recognised optimal
survey season of April to September in accordance with the Bat Surveys for Professional
Ecologists – Good Practice Guidelines (Collins, 2016). The surveys included daytime
roost assessments together with dusk acoustic monitoring using automated bat
detectors. No bat roosts were identifled, and no bat activity was recorded within the
development footprint.
Red Squirrels and Other Mammals
Observations refer to the absence of a dedicated red squirrel assessment. The
Biodiversity Chapter assessed the habitats within the Zone of Infiuence and their
suitability for protected mammals, together with the potential effects of the Proposed
Development on those habitats. The Proposed Development site consists
predominantly of improved agricultural grassland with fragmented hedgerows and
limited woodland habitat. Having regard to the nature of the habitats present and the
proposed mitigation measures, the Biodiversity Chapter concludes that no signiflcant
adverse effects on protected mammals are anticipated.
Frogs, Smooth Newts, Common Lizards and Wetlands
Concerns have been raised regarding nearby wetlands and the suggestion that it
provides important frog spawning habitat. The assessment completed included surveys
for amphibians undertaken during the recognised activity season. No permanent
waterbodies suitable for amphibian breeding occur within the proposed development
site. Surveys nevertheless examined drainage features and adjacent habitats on a
precautionary basis.
Potential indirect effects through changes in water quality were assessed in conjunction
with Chapter 10 (Water). The proposed development incorporates comprehensive
surface water management measures, pollution prevention measures and construction
controls. The Biodiversity Chapter concludes that, following implementation of these
measures, no signiflcant adverse effects on downstream aquatic habitats or amphibian
populations are anticipated.
Furthermore, the previously proposed Soil Relocation Area no longer forms part of the
Proposed Development. The hydrological and hydrogeological assessment submitted in
response to the Further Information Request concluded that there is no identifled
hydrogeological linkage by which the Proposed Development could alter the
hydrological balance of Drumintin Wetland or any other surrounding wetland feature.
Ecological Connectivity
A number of observations suggested that the Proposed Development would fragment
ecological corridors and reduce habitat connectivity. These matters were speciflcally RECEIVED: 28/08/2026
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considered in Chapter 11 of the EIAR. The design retains the majority of existing
boundary hedgerows and treelines, with additional native planting proposed to
reinforce retained corridors and reconnect sections where localised removal is
required. Consequently, while some localised habitat loss will occur, ecological
connectivity within the wider landscape will be maintained and strengthened over the
longer term through the proposed enhancement planting and management measures.
Conclusion
Overall, the proposed development has been designed to avoid and minimise impacts
on biodiversity through the retention of existing habitats wherever practicable,
implementation of a Construction Environmental Management Plan, appointment of an
Ecological Clerk of Works, pre-construction ecological inspections, sensitive lighting
design, protection of water quality and the creation of substantial new native planting
and wildlife habitat.
The detailed ecological assessment concludes that, following implementation of these
measures, the proposed development will not result in signiflcant adverse effects on
biodiversity, protected species or ecological connectivity. In several respects,
particularly through the creation and long-term management of native woodland and
hedgerows, the project will provide a net enhancement of habitat within the site.
RECEIVED: 28/08/2026
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Cultural Heritage
Points Raised
The third-party submissions raise concerns regarding potential effects on archaeology,
architectural heritage and the wider cultural landscape. A range of archaeological
monuments, historic sites and cultural heritage receptors are identifled, including Black
Pig’s Dyke, the Maghernakelly hilltop enclosure, ringforts and other enclosures, Edergole
Giant’s Grave, the Drumgole Grey Stones, Drumgole crannog, Drumanny souterrain, New
Park House, Dartry Forest, the Dawson Monument and Dawson Demesne, Freame Mount
Demesne, Bellamont House and the Tyrone Guthrie Centre.
Some submissions contend that archaeological or heritage features have been omitted
from, or inaccurately described in, the application documentation and raise concerns
regarding potential direct and indirect effects on archaeological remains, historic
landscapes, the setting of heritage assets and the wider cultural heritage value of the
area. It is also contended that the Proposed Development would be inconsistent with
relevant heritage protection policies of the Monaghan County Development Plan.
Response
Matters relating to cultural heritage have been assessed within Chapter 15 Cultural
Heritage of the EIAR. The assessment was prepared by suitably qualifled archaeological
and built heritage specialists (Courtney Deery) in accordance with the National
Monuments Acts, the Planning and Development Act 2000 (as amended), the EPA
Guidelines on the Information to be Contained in Environmental Impact Assessment
Reports (2022), the Transport Infrastructure Ireland Guidelines for Cultural Heritage
Impact Assessment (2024), and other recognised national and international guidance.
The assessment was also undertaken having regard to the heritage objectives of the
Monaghan County Development Plan 2025–2031.
The assessment comprised:
• Comprehensive desk-based assessment;
• Consultation of the National Monuments Service, National Inventory of
Architectural Heritage (NIAH), Record of Protected Structures (RPS), historic
mapping, aerial photography and published archaeological sources;
• Site inspections;
• Geophysical survey of the development site; and
• Targeted archaeological test excavation undertaken under licence.
Further assessment is also provided in Sections 2.3 to 2.5 of the RFI response, which
addresses a request for further archaeological trenching and queries raised around the RECEIVED: 28/08/2026
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relationship between the nearby hilltop enclosure and Drumgole Grey Stones, and the
nearby New Park landed estate.
Proximity to Archaeological and Cultural Heritage Sites
A number of submissions refer to the proximity of the proposed development to
archaeological monuments and cultural heritage sites. Importantly:
• There are no recorded monuments within the proposed development;
• There are no national monuments or sites under preservation order within 1 km of
the site;
• There are no protected structures within 1 km of the site; and
• There are no architectural conservation areas within 1 km of the site.
The EIAR speciflcally identifled and assessed all designated archaeological and
architectural heritage assets within an appropriate study area surrounding the proposed
development, including:
• Maghernakelly Hilltop Enclosure (RMP MO022-008);
• Drumgole Grey Stones (MO017-068);
• Ringforts and associated souterrains at Drumanny and Maghernakelly;
• Crannog sites within the wider landscape;
• New Park House and the former New Park Estate;
• Dartrey Estate and associated built heritage features;
• Dawson Grove Demesne and Freame Mount Demesne;
• Other heritage assets identifled through NIAH, RPS, RMP and historic mapping
reviews.
Several of the features referenced in submissions are located considerable distances
from the proposed development. For example:
• The Black Pig's Dyke is approximately 10 km from the site. (there is no recorded
section of the Black Pig’s Dyke within the application site).
• The Edergole Court Tomb ("Giant's Grave") is approximately 4.2 km from the site.
• The Drumanny ringfort and souterrain are approximately 935 m from the proposed
biogas plant.
• The Drumgole stone row ("Grey Stones") is approximately 795 m from the proposed
biogas plant.
Given these distances and the intervening drumlin topography, no direct effects on
these monuments will arise. RECEIVED: 28/08/2026
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The EIAR concluded that the only recorded monument likely to experience a potential
setting effect is the Maghernakelly Hilltop Enclosure (MO022-008), located
approximately 185 m southwest of the proposed biogas plant at its closest point. This
effect is limited to a change in views toward the northeast and does not affect the
monument itself, its physical fabric, archaeological integrity, or any known intervisibility
with other monuments. The resulting residual effect was assessed as an indirect
moderate visual and setting impact only.
Further assessment work was undertaken in response to RFI Point 4 to address
potential for intervisibility between the hilltop enclosure and the stone row (RMP
MO017-068). This included a site visit and preparation of a photomontage which
demonstrated that the existing fleld boundary adjacent to the stone row, even without
summer foliage, will largely obscure the proposed development from view at the stone
row. There will be no impact on the setting of the stone row. It was also noted that there
is no reason to assume that any such connection would have been important in the
context of these two monuments in the past. While both are may be prehistoric, there is
no evidence that they are contemporary.
Archaeological Remains
Some submissions suggest that archaeological features have been omitted or
inadequately assessed, which is not correct. The Cultural Heritage assessment was
prepared following consultation of the relevant statutory datasets, including the
National Monuments Service Record of Monuments and Places, the National Inventory
of Architectural Heritage, the Record of Protected Structures, historic mapping, aerial
photography and other published archaeological sources.
These desk-based studies were supplemented by fleld inspection and archaeological
investigations undertaken speciflcally for the proposed development. Accordingly, the
assessment provides a comprehensive evaluation of the known archaeological and
cultural heritage resource within the study area.
Prior to the submission of the planning application, the Applicant commissioned a
detailed programme of archaeological investigation which included:
• Geophysical survey across the development footprint (September 2024);
• Initial archaeological test excavation comprising nine trenches totalling
approximately 232 linear metres (June / July 2025); and
• Follow-up archaeological test excavation comprising eleven trenches totalling
approximately 360 linear metres (June 2026) (refer to RFI Point 3 response)
The investigations demonstrated that the majority of the geophysical anomalies
represented former fleld boundaries or modern agricultural activity. RECEIVED: 28/08/2026
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One archaeological feature was identifled during the initial test excavation works,
comprising the truncated remains of a prehistoric fulacht fladh (burnt mound and
trough), a relatively common Bronze Age archaeological feature. This feature was
further deflned and its extents conflrmed during the follow-up test excavations (3m x
2.8m, 0.1m deep).
The EIAR recognises that construction will directly affect the identifled fulacht fladh
within the application site and, rather than avoiding this issue, the assessment explicitly
identifles the impact and assesses its signiflcance in accordance with the EPA and TII
guidance. Appropriate archaeological mitigation comprising preservation by record
through full licensed archaeological excavation of this feature (AA1) prior to relevant
works, with archaeological monitoring of initial ground disturbance elsewhere, will be
implemented.
Apart from this identifled archaeological feature, the detailed assessments concluded
that no recorded monuments (including Black Pig’s Dyke) occur within the application
site and no direct impacts on designated archaeological monuments are predicted.
Historic Landscape
Observations suggest that the development would adversely affect the setting of nearby
monuments, particularly the Maghernakelly Hilltop Enclosure.
The EIAR speciflcally assessed the setting of this monument using fleld surveys together
with dedicated cultural heritage photomontages prepared for that purpose. The
assessment concludes that the proposed development will be visible from the hilltop
enclosure and will alter views towards the north-east. However, the monument will
retain its elevated position, its principal archaeological characteristics, and its wider
relationship with the surrounding landscape. Importantly, the development will not
interrupt intervisibility between the hilltop enclosure and other archaeological
monuments within the surrounding landscape. It is also noted that the location of the
proposed development at the base of the drumlin landform limits its wider visibility
within the landscape.
In relation to New Park House and the former New Park Demesne (refer to RFI Point 5
response), the assessment concludes that the proposed development site occupies
agricultural flelds to the rear of the former estate rather than the historic designed
parkland associated with the house.
The area containing the proposed development does not contribute to the signiflcance
of the house or its setting, and given the absence of any landscape design features or
historic landscape character in this part of the estate, it is considered that there would
be a slight direct negative effect on this low sensitivity receptor. The surviving designed RECEIVED: 28/08/2026
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southward facing landscape associated with New Park House will therefore be
unaffected by the proposed development.
Conclusion
In summary, the assessments completed conflrm that there are no Recorded
Monuments within the application site and identifled one previously unknown
prehistoric archaeological feature, allowing appropriate mitigation to be incorporated
into the project before development commences.
The EIAR concludes that, following implementation of the proposed archaeological
mitigation, the proposed development will not result in signiflcant adverse effects on
the wider archaeological, architectural or cultural heritage resource, and has been
designed in a manner that is consistent with the heritage objectives of the Monaghan
County Development Plan.
RECEIVED: 28/08/2026
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Site Selection and Location
The third-party submissions raise concerns regarding the suitability of the site selected
for the Proposed Development. A number of submissions refer to the proximity of existing
residential properties and public roads and contend that anaerobic digestion or biogas
facilities should be subject to minimum separation distances from sensitive receptors,
with some submissions referring to suggested distances of 300–500 m. It is argued that
facilities of this nature would be more appropriately located on zoned industrial or
brownfleld lands and that alternative sites are available. Concerns are also raised
regarding the absence of speciflc national siting guidance and mandatory setback
requirements for biogas development, with some submissions contending that
determination of such proposals in advance of anticipated further guidance is
premature. Reference is made to the IrBEA Planning Guidance Recommendations for
Bioenergy Projects in Ireland, with submissions asserting that the site does not satisfy
the locational criteria identifled in that guidance. Other observations question the extent
of the site-selection exercise, including whether locations closer to potential users of
digestate were considered, and contend that the Proposed Development has not
demonstrated consistency with the National Planning Framework or relevant Monaghan
County Development Plan policies concerning the location of such facilities, including
policies relating to settlement boundaries and proximity to a flxed resource.
Response
The location of the proposed biogas plant was not selected arbitrarily. A comprehensive
alternatives assessment was undertaken and documented in Chapter 3 (Alternatives) of
the EIAR. The assessment was prepared in accordance with the requirements of the EIA
Directive and EPA Guidelines and considered alternative regions, search areas and
individual sites before identifying the preferred site. While technical and operational
feasibility formed part of the overall assessment, environmental effects were the
primary differentiator in selecting the preferred site.
Separation Distances from Residential Properties
An observation was received stating that European standards require biogas plants to
be located between 300 m and 500 m from residential properties. There are no
prescribed mandatory separation distances of this nature for biogas plants. The current
National Waste Management Plan for a Circular Economy (2024–2030), which contains
speciflc siting guidance for biological treatment facilities including biogas plants,
recognises that residential properties may be located within 100 metres of a plant
where appropriate mitigation demonstrates that there will be no unacceptable impacts
in relation to air quality, odour, noise, visual amenity or human health.
The proposed development has been accompanied by detailed specialist assessments
of air quality and odour, noise and vibration, traffic and transport, landscape and visual RECEIVED: 28/08/2026
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impact, biodiversity, water quality and population and human health. Each of these
assessments concludes that, following implementation of the proposed mitigation
measures, no signiflcant adverse residual effects are predicted.
Accordingly, the acceptability of the proposed location falls to be determined on the
basis of the detailed technical assessments submitted with the application and the
relevant planning policy framework, rather than by reference to arbitrary setback
distances that do not form part of Irish planning policy or legislation.
Suitability of the Rural Location
Several observations suggest that biogas facilities should only be located on industrially
zoned land or brownfleld sites.
The Applicant respectfully disagrees with this assertion. Anaerobic digestion facilities
processing agricultural feedstocks are fundamentally different from general industrial
development, as their location is driven by the need to remain close to feedstock
sources, digestate end users and gas infrastructure, consistent with the proximity
principle.
The National Waste Management Plan expressly recognises that biogas plants serving
the agricultural sector are appropriately located in rural areas and on agricultural land,
close to their principal feedstock source, the gas network and areas where digestate
can be beneflcially reused. The Plan also incorporates the Proximity Principle, requiring
biological treatment facilities to be located as close as practicable to the waste streams
they process in order to minimise transport-related environmental effects.
The proposed development has been speciflcally designed to process poultry manure,
cattle slurry and agri-food by-products generated within County Monaghan and the
surrounding area. The selected location is close to the principal feedstock resource,
adjacent to the regional road network and within an appropriate distance of the existing
Gas Networks Ireland infrastructure, thereby satisfying these key national siting
principles.
Consideration of Alternative Sites
A comprehensive site selection exercise was carried out to identify the chosen site. The
site selection process comprised four stages:
• Identiflcation of the most appropriate region based on feedstock availability;
• Identiflcation of suitable search areas having regard to the existing gas network;
• Assessment of a number of alternative sites; and
• Detailed comparative environmental assessment of the preferred sites. RECEIVED: 28/08/2026
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County Monaghan was identifled as the preferred region because it contains the highest
concentration of poultry production in Ireland and therefore the largest available supply
of poultry manure, which forms the principal feedstock for the proposed facility.
The search was then reflned to areas close to the existing gas network because direct
gas grid injection was identifled as the most sustainable and environmentally beneflcial
method of exporting biomethane.
Potential sites in both the Lough Egish and Cootehill areas were considered. Lough
Egish was discounted due to the presence of environmental constraints including
designated landscape and ecological sensitivities together with the absence of a
commercially available site.
Within the Cootehill search area, a number of potential sites were assessed. Several
were rejected because of longer transport distances, the need for HGV traffic to travel
through Cootehill town, heritage constraints or greater environmental impacts.
Following detailed environmental assessment, the proposed site emerged as the
preferred location because it demonstrated the lowest overall environmental
constraints.
Consistent with the EIA Directive and EPA guidance, the alternatives assessment
considered the full range of reasonable alternatives available to the Applicant at the
time of site selection. The assessment was necessarily limited to sites that could
realistically be secured, as landowner agreement is an essential prerequisite to delivery
of any project.
One submission suggested that sites further south should have been considered to
reduce transport of digestate. However, site selection requires a balanced
consideration of feedstock availability, proximity to the gas network, transport
infrastructure and areas where digestate can be beneflcially reused. The selected
location refiects this balance rather than optimising a single factor in isolation.
Compliance with Policy
Observations suggest that the proposed development confiicts with the Monaghan
County Development Plan in terms of the proposed location. This is not supported by
the Development Plan.
The Alternatives Assessment speciflcally reviewed the relevant policies of the
Monaghan County Development Plan and notes that the Plan recognises the signiflcant
contribution bioenergy can make towards renewable energy generation, climate action,
rural development and environmental improvement. The Plan also states that
bioenergy developments will be considered on a case-by-case basis having regard to
planning and environmental considerations and supports renewable energy proposals RECEIVED: 28/08/2026
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where it is demonstrated that they will not give rise to unacceptable impacts on
residential amenity or other environmental receptors.
In addition to complying with Monaghan County Council policy, the proposed
development also directly supports the objectives of the National Planning Framework,
the National Development Plan, the Climate Action Plan, the National Biomethane
Strategy and the National Waste Management Plan by:
• Supporting the transition to renewable energy;
• Promoting the circular economy;
• Reducing greenhouse gas emissions;
• Providing sustainable management of agricultural organic materials;
• Supporting rural enterprise; and
• Reducing reliance on imported fossil fuels.
Accordingly, the Alternatives Chapter provides clear evidence that the chosen site was
selected after comparing reasonable alternatives against environmental criteria, which
is exactly what both the EIA Directive and National and local policy require.
Confiict with IrBEA Guidance
A number of submissions contend that the proposed development does not comply
with the Irish Bioenergy Association (IrBEA) publication Planning Guidance
Recommendations for Bioenergy Projects in Ireland. The Applicant does not agree with
this interpretation of the IrBEA guidance. In this regard we note the formal submission to
Monaghan County Council by the CEO of IrBEA in support of the proposed
development.
The submission explains that the guidance merely provides examples of sites which
may be "open to consideration" for large-scale projects and that these examples are not
recommendations. Furthermore, the examples are not exhaustive and do not represent
every suitable site option.
IrBEA further conflrms that biogas plants have been successfully developed on both
greenfleld and brownfleld sites throughout Ireland and Europe. Accordingly, the IrBEA
guidance does not require, or even recommend, that all biogas developments should be
located on brownfleld or industrial sites.
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Other Matters Raised
The third-party submissions also raise a number of procedural and ancillary concerns. It
is alleged that works associated with, or connected to, the Proposed Development were
undertaken on adjoining agricultural lands prior to submission of the planning
application, including hedgerow removal and drainage works in an area described in
submissions as bogland. Concerns are also expressed regarding the extent and timing of
pre-application engagement with the local community. A number of residents contend
that meaningful consultation did not take place and that they received only
approximately two weeks’ notice before the planning application was lodged, which they
state gave rise to upset and frustration within the local community.
Response
Activity on Adjacent Site Prior to Submission of Application
The Applicant conflrms that the works referred to in observations were undertaken on
lands outside the application site and do not form part of the Proposed Development.
These works were unrelated to the planning application and did not inform, facilitate or
prejudice the environmental assessments undertaken as part of the EIAR. Accordingly,
they have no bearing on the planning merits of the Proposed Development..
Public Consultation
The Applicant respectfully disagrees with the suggestion that meaningful consultation
did not take place prior to submission of the planning application..
Prior to submission of the application, the Applicant implemented a structured
programme of stakeholder and community engagement designed to provide
information on the Proposed Development, facilitate questions and allow residents to
engage directly with the Applicant and specialist consultants.
This included:
• Meeting with Ballybay-Clones Municipal District Councillors on 17 November 2025
to inform members of key elements of the proposal.
• Direct resident Notification: Residents within 1 km of the proposed Renewable
Biogas Plant were contacted directly by the landowner over the days following the
Municipal District brieflng. Each household received an information leafiet outlining
the nature and purpose of the project, the key design elements, and the anticipated
planning timeline. The leafiet also provided a dedicated project email address to
allow residents to contact the Applicant directly with questions or requests for
further information.
• Visits to Tully Plant: Local residents were invited to attend study visits to the
Applicant’s operational Tully Biogas Plant in Ballymena, Co. Antrim. This facility RECEIVED: 28/08/2026
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processes similar feedstocks to those proposed for the subject project and provided
an opportunity for residents to observe an established plant in operation, meet
facility operators, and discuss aspects such as odour control, traffic, noise, and
overall site management. Two visits were arranged in December 2025 and January
2026 to ensure as many residents could visit as possible.
• Local Information Event: The Applicant organised a local public information
evening. Hand-delivered invitations were issued to each household within 1km on
3rd December 2025, setting out the date, time, and location of the event. The
information evening took place on 9th December 2025 and was attended by 62 local
residents and interested stakeholders. The event was run as an informal drop-in
session, allowing attendees to view display boards, maps, and explanatory material
at their own pace. Members of the project team from Stream and their
environmental and technical consultants were present throughout to answer
questions and discuss the proposal in detail. Following the information event, the
Applicant remained available to respond to queries from residents, facilitate
meetings where requested and provide clariflcations when requested.
• Project Website: To support ongoing access to information, a dedicated project
website was established: www.monaghanbiogas.com. The website provides an
overview of the project, frequently asked questions, explanatory material on
anaerobic digestion, and a contact facility for residents and interested stakeholders.
This platform has remained active throughout the planning process to ensure
continued transparency and ease of access to project information.
The purpose of consultation is to provide information, listen to concerns and enable
informed participation in the planning process. The Applicant considers that the
programme of engagement undertaken prior to and during the application process
provided multiple opportunities for local residents to obtain information, raise issues
directly with the project team and enabled concerns raised by residents to be
considered by the Applicant and project team during the application and Further
Information processes.
While observations refer to the period between notiflcation and submission of the
application, there is no statutory minimum period for pre-application community
consultation for developments of this nature. Nevertheless, the Applicant undertook
voluntary engagement in advance of the application, provided opportunities for
residents to obtain information and ask questions, and maintained communication
channels throughout the process.
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