HomeMy WebLinkAbout2660018 - F.I. Received Doc. - Response to third party Submissions
STR010/0001-#9436218v1
Response to RFI Question 9
Item 9 of the RFI requests:
“An Taisce have commented on the proposed development and have raised several
concerns under the headings of;
i. Feedstocks
ii. Methane Leakage
iii. End- Use of Digestate
iv. Fossil Gas Lock-in
v. Wetland proximity
vi. Traffic Impact Assessment
The applicant is requested to review the full content of An Taisce’s submission and
provide a detailed and comprehensive response to each issue raised.”
Feedstocks
An Taisce: The application is for a biogas facility to process up to 99,000 tonnes per
annum of predominantly poultry manure (80,000-99,000 tonnes), cattle manure (2,000-
10,000 tonnes) and agri-food organic waste (9,000-19,000 tonnes).
It must be determined that proposed feedstocks are sustainable in the flrst instance and
that their production will not exacerbate ongoing issues with greenhouse gas emissions,
water quality deterioration, etc. The emissions that contribute to the production of
feedstocks must be considered as indirect impacts of the proposal as they can
signiflcantly negatively impact biomethane’s overall contribution to climate mitigation.
As producing sustainable energy is a key justiflcation used by the applicant in thi s case,
assessing the indirect impacts of the feedstocks is crucial.
It should be ensured that the proposal does not indirectly drive further poultry agriculture
intensiflcation due to the consistent provision of feedstock given the cumulative
ammonia air quality impacts, water quality impacts from run-off and biodiversity
implications.
Response
The Applicant has reviewed the An Taisce submission in full. The response below
addresses each of the matters identifled and should be read together with the revised
suite of information submitted as part of this Further Information response. RECEIVED: 28/08/2026
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References to the Proposed Development relate to the Renewable Biogas Plant and
associated works for which permission is sought; where relevant, the wider Proposed
Project includes the separately delivered Linear Gas Grid Connection for EIA and
Appropriate Assessment purposes.
The waste feedstocks proposed for use in the generation of renewable energy at the
proposed development arise from agricultural and agri-food activities that are essential
to food production. In County Monaghan alone, in excess of 250,000 tonnes of poultry
manure is already generated annually1, signiflcantly exceeding the 80,000–99,000 tonnes
per annum required by the proposed development. For clarity, the individual feedstock
ranges are indicative and not additive; the total combined annual feedstock intake will
not exceed 99,000 tonnes per annum.
The Proposed Development does not require an expansion of poultry or other agricultural
production. It is designed to treat materials already arising from the established
agricultural and agri-food sector.
While the proposed facility will receive feedstock generated by existing farming and agri-
food operations, the Supreme Court's judgment in An Taisce (Kilkenny Cheese)2
conflrmed that separate upstream agricultural activities do not require assessment as
indirect effects of a project where the alleged effects are too remote, contingent or
speculative and are not an integral part of the proposed development.
The feedstocks in question are by-products and waste materials arising from existing
activities that will continue to be generated irrespective of whether the proposed biogas
plant proceeds. Accordingly, the environmental effects associated with those activities
are not effects of the proposed development itself.
Furthermore, the activities that generate these materials are subject to oversight and
regulation under separate statutory and regulatory regimes. The relevant competent
authorities include Monaghan County Council, the Department of Agriculture, Food and
the Marine (DAFM) and the Environmental Protection Agency (EPA). As such, these
activities do not require assessment within the EIAR prepared for the proposed
development. Stream BioEnergy will ensure that all feedstocks received at the plant and
any materials produced from the anaerobic digestion process are managed in
compliance with all relevant legislative and environmental requirements.
Notwithstanding the above, the proposed development will provide a local solution to the
management of existing poultry and cattle manure and other agri-food organic wastes
produced in Co. Monaghan that will help to reduce greenhouse gas emissions and
1 Baseline Study Report on the Poultry Sector within Co. Monaghan, prepared by Fehily Timoney
Consultants
2 An Taisce v An Bord Pleanála & Kilkenny Cheese, [2022] IESC 8 RECEIVED: 28/08/2026
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improve water quality in local river and streams, rather than exacerbating any existing
issues.
The proposed facility will treat incoming waste materials in a more environmentally
friendly manner compared to current management practices, with the plant producing
safer and more environmentally stable and sustainable fertiliser products compared to
the baseline impacts of using raw manures or artiflcial fertilisers. The main beneflts of
the sustainable fertilisers that will be produced by Stream include:
• Pasteurised in accordance with DAFM requirements, removing any potential
biosecurity issues (i.e. salmonella, E. coli, botulism risk) associated with raw
manures.
• Fully tested with labelled nutrient values, enabling precise application rates by
farmers in response to crop needs and reducing the pollution risks of inaccurate
application.
• Low carbon footprint to help meet food purchaser’s Scope 3 compliance targets.
• Carbon content of Stream fertilisers binds the nutrients within them, hence enabling
slow nutrient release and higher use efficiency leading to lower application rates.
• Stream fertilisers will enable better nutrient uptake thereby resulting in improvements
to soil and water quality, as well as reducing harm to biodiversity.
Overall, sustainable fertilisers produced at the plant will help to reduce greenhouse gas
emissions and improve water quality. In relation to the point on potential intensiflcation
of the poultry sector, the plant will have capacity to treat less than 40% of the available
poultry manure already being generated by the sector, therefore it will not indirectly lead
to intensiflcation but will help to address an existing challenge.
Methane Leakage
The proposed plant will be a state-of-the-art development utilising Best Available
Techniques (BAT), modern process control systems and robust engineering standards.
The facility will operate in strict accordance with applicable environmental, health and
safety legislation and will be regulated through an EPA Industrial Emissions Licence
together with the relevant requirements of the Health and Safety Authority (HSA). These
regulatory controls are speciflcally designed to protect both human health and the
environment.
In relation to potential methane leakage, the proposed facility has been designed on the
principle of preventing fugitive emissions through enclosed process systems, engineered
containment, continuous process monitoring, preventative maintenance and routine
inspection.
As outlined in the National Biomethane Strategy (2024), the Biomethane Working Group
will develop best practice guidance for methane management across the biomethane RECEIVED: 28/08/2026
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sector. Stream BioEnergy already places signiflcant emphasis on methane containment
and will review its operating procedures as these national guidelines are published to
ensure that operational practices continue to refiect industry best practice.
The plant will incorporate a Supervisory Control and Data Acquisition (SCADA) system
providing continuous real-time monitoring of key process parameters, including gas
production, gas consumption and process performance. This allows operators to identify
abnormal operating conditions at an early stage and initiate corrective actions before
they develop into more signiflcant issues.
However, methane management is not dependent solely on automated monitoring. The
facility will operate under a comprehensive preventative maintenance and inspection
programme speciflcally designed to minimise the potential for fugitive methane
emissions.
Routine operational inspections will include daily and weekly inspections of the
complete gas handling system, including:
• Digesters and gas-tight covers;
• Gas storage domes;
• Gas upgrading equipment;
• Gas compressors and gas treatment equipment;
• Gas dewatering systems;
• Gas fiare equipment;
• Over-pressure and under-pressure protection devices;
• Gas pipework, valves and associated flttings; and
• Gas seals, shaft seals and water locks.
These inspections include documented checks for any evidence of gas leakage, unusual
odours, abnormal operating conditions, damage, vibration, pressure anomalies or
deterioration of gas handling infrastructure. Digester methane concentrations and
hydrogen sulphide concentrations are also routinely recorded as part of the operational
inspection regime.
Automatic flxed gas detection equipment will be installed within areas where elevated
gas concentrations could potentially occur. These detectors form part of the plant safety
system and provide continuous monitoring, with alarms generated immediately should
predetermined gas concentration thresholds be exceeded. The SCADA system provides
continuous monitoring of plant performance and alerts operators to abnormal operating
conditions requiring investigation and corrective action.
Where inspections, gas monitoring or alarms identify any abnormal condition or
evidence of leakage, established leak detection and repair (LDAR) procedures will be
implemented. These procedures include immediate investigation of the affected RECEIVED: 28/08/2026
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equipment, isolation of plant where necessary, repair or replacement of defective
components, veriflcation that repairs have been successfully completed and recording
of all inspections and corrective actions within the plant maintenance management
system before equipment is returned to normal service.
The maintenance strategy adopts a preventative rather than reactive approach. Critical
gas handling infrastructure is subject to scheduled preventative maintenance, routine
servicing and periodic inspection in accordance with manufacturer recommendations
and site-speciflc maintenance procedures. Where critical equipment has been identifled
as representing a higher operational risk, additional maintenance measures are
implemented, including priority maintenance scheduling, retention of critical spare parts
on site, provision of bypass arrangements where appropriate and alternative operating
conflgurations to minimise the likelihood of equipment failure.
Speciflc measures identifled within the maintenance strategy include:
• Regular inspection and servicing of the gas dewatering system together with spare
pumps, sensors and contingency arrangements to maintain gas management;
• Weekly operational testing of the emergency gas fiare, together with annual inspection
and testing by the equipment manufacturer or authorised service agent;
• Routine inspection of gas storage infrastructure, gas-tight covers, pressure relief
systems and associated pipework as part of the plant's daily and weekly preventative
maintenance inspections; and
• Routine inspection of agitator shaft seals, water locks, over-pressure and under-
pressure valves, ventilation systems and gas pipework to verify the continued integrity
of the gas containment system.
The facility will also implement documented operational procedures governing methane
management, including routine operator inspections, preventative maintenance, gas
monitoring, leak detection, emergency response, equipment isolation where required,
maintenance recording and veriflcation that repairs have been successfully completed
prior to recommissioning equipment.
Overall, methane containment will be actively managed through multiple independent
layers of protection comprising engineered containment, continuous process
monitoring, automatic gas detection, routine preventative maintenance, documented
leak detection and repair procedures, scheduled inspection of all gas handling
infrastructure and ongoing regulatory oversight by the EPA and the Health and Safety
Authority.
Accordingly, the Proposed Development incorporates multiple independent layers of
engineering, monitoring, inspection and maintenance controls speciflcally directed at
preventing and minimising fugitive methane emissions and ensuring that any abnormal
operating condition or evidence of leakage is identifled and rectifled promptly. Methane RECEIVED: 28/08/2026
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leakage is not an intended or routine emission from the process and will be actively
managed throughout operation through the plant's gas-containment systems, SCADA
monitoring, preventative maintenance and leak detection and repair procedures,
together with the regulatory requirements applicable to the facility.
The Applicant acknowledges that effective methane management is important to
maintaining the greenhouse gas beneflts associated with renewable biomethane
production. This is precisely why methane containment and leak prevention have been
treated as fundamental elements of the plant design and operational management
regime. The Proposed Development has therefore been designed to minimise the
potential for uncontrolled methane losses throughout the production, storage, upgrading
and handling process.
End-Use of Digestate
As outlined in Chapter 1 of the EIAR, end-use of digestate that will be produced at the
plant is a downstream activity and is not part of the development for which consent was
sought in the application. The application of these materials will be appropriately
managed under a separate regulatory regime designed to mitigate environmental risks
and ensure sustainable land management practices. The principal elements of this
regulatory framework include:
• The Nitrates Directive (91/676/EEC), as transposed into Irish law by the Good
Agricultural Practice for Protection of Waters Regulations (S.I. No. 113 of 2022), as
amended;
• The Nitrates Derogation Terms and Conditions (where applicable);
• The Department of Agriculture, Food and the Marine (DAFM) Code of Good Agricultural
Practice for Reducing Ammonia Emissions from Agriculture;
• Inland Fisheries Ireland’s Code of Practice for the Protection of Waters; and
• Any other applicable environmental, agricultural and water quality protection
legislation in force at the time of digestate application.
As the operator of the facility, Stream is committed to ensuring that digestate from the
site is managed in compliance with all relevant legislative and environmental
requirements. However, because the identity of receiving lands and future nutrient
demands cannot be established years in advance, requiring detailed nutrient
management plans or conflrmed landbanks at planning stage would be both
impracticable and inconsistent with existing case law (Kemper3, Kilkenny Cheese4 and
Sweetman5). Instead, these matters are appropriately addressed through the existing
3 Kemper v An Bord Pleanála [2020] IEHC 601
4 An Taisce v An Bord Pleanála [2022] IESC 8
5 Sweetman v EPA [2025] IECA 49 RECEIVED: 28/08/2026
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agricultural regulatory framework at the point when digestate is produced and proposed
for application to land.
Reference in the An Taisce submission to Wanier et al and further commentary around
the application of liquid digestate and potential for water pollution is not relevant to the
proposed development, as the proposed facility has not been designed to produce or
export untreated liquid digestate. Rather, the plant incorporates dedicated digestate
treatment processes to convert the digestate into stable, marketable fertiliser products
suitable for transport and beneflcial reuse.
An extract from Table 2-4 (Chapter 2) of the EIAR outlining the digestate products that will
be produced by the plant is provided below for information purposes.
Table 0-1 By-Products of the AD Process
Product Annual Quantity Likely Application
Fibre digestate Up to 60,000 tonnes These sustainable fertiliser products will be derived from
pasteurised digestate and will be suitable for application in
the agri-food sector, whether in horticulture or agriculture.
They can be applied for safe use wherever there is a
suitable need for the nutrients. This creates an excellent
circular economy use for these materials that offsets the
need for synthetic fertilisers.
Dried fertiliser / pellets Up to 7,000 tonnes
Ammonium sulphate Up to 9,000 tonnes
This Table demonstrates that the literature cited by An Taisce concerning the direct land
application of untreated liquid digestate does not refiect the digestate treatment and
product-management arrangements proposed in this application.
A key objective of the proposed development is to convert poultry manure, which is
currently concentrated within County Monaghan, into stable, high-quality fertiliser
products that can be transported economically and exported to areas where there is a
genuine nutrient demand. This represents a signiflcant environmental beneflt of the
proposed development by facilitating the redistribution of nutrients from areas of surplus
to areas of deflcit, thereby reducing nutrient pressures within the region while supporting
the circular economy.
Signiflcant technical design and investment will be put into the production of these
sustainable fertiliser products, that can be used instead of artiflcial fertilisers thereby
offsetting signiflcant GHG emissions and allowing the production of low carbon food.
Importantly, the digestate treatment processes proposed are not simply storage or
handling operations. They are speciflcally designed to transform digestate into stable and
marketable fertiliser products. Digestate treatment processes employed at the site will
include pasteurisation, separation (producing flbre digestate), evaporation and drying
(producing a pellet). Ammonium sulphate will be produced as a by-product of the
ammonia stripping process. These treatment processes improve the physical handling
characteristics of the products, enhance their suitability for transport over longer RECEIVED: 28/08/2026
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distances, reduce the volume requiring transport and produce fertiliser products that can
be beneflcially reused in agriculture and horticulture in accordance with the applicable
regulatory framework.
These processes have been included in the site design to enable the export of nutrients
away from Co. Monaghan as required. Accordingly, the proposed development should
not be viewed as simply processing poultry manure, but as recovering nutrients in a form
that enables their beneflcial reuse elsewhere, thereby reducing reliance on imported
synthetic fertilisers and supporting Ireland's transition to a more circular and resource-
efficient agricultural economy.
The overall environmental assessment should therefore recognise that the project
provides signiflcant environmental beneflts when compared with the existing
management of poultry manure within the region. These beneflts include the recovery of
nutrients from organic waste streams, the production of renewable fertiliser products,
the export of surplus nutrients from an area of nutrient surplus, the displacement of
carbon-intensive synthetic fertilisers and the reduction of greenhouse gas emissions
associated with both manure management and fertiliser manufacture.
In relation to commentary around assessment of the project against Article 4 of the Water
Framework Development (WFD), a WFD Screening Assessment for the project was
submitted as Appendix 10.3 of the EIAR. This assessment concluded that the proposed
development will not result in any deterioration in the status of any surface water body or
groundwater body, will not prevent any waterbody from achieving its Water Framework
Directive objectives, and is therefore consistent with the requirements of Article 4 of the
Water Framework Directive.
Fossil Gas Lock-In
An Taisce: The proposal also seeks to provide biogas to the centralised gas grid via an
underground connection pipeline. However, injection of the biomethane into the grid for
mixing with fossil gas will exacerbate infrastructural lock-in to fossil fuel use in the
medium to long term which is incompatible with our emissions reduction legal
obligations. By seeking to maintain a form of gas dependency, it is submitted that the
proposal may run counter to the goals of the Paris Agreement as well as European and
national climate policy and legislation to rapidly phase out reliance on fossil fuels.
It is therefore submitted that supplying the biomethane to local off-grid industrial users
would be a preferable option, provided it is used for electricity generation and is not mixed
with fossil gas.
Response RECEIVED: 28/08/2026
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Grid injection is expressly contemplated by the National Biomethane Strategy as part of
the national pathway for scaling biomethane production and integrating renewable gas
into Ireland's existing energy system.
The submission in relation to fossil gas lock-in suggests that injection of biomethane into
the gas network would exacerbate dependence on fossil fuels and create long-term fossil
fuel lock-in. This characterisation does not accurately refiect the purpose or effect of the
proposed development.
The proposed plant will produce renewable biomethane from organic feedstocks. When
injected into the gas network, this biomethane directly displaces an equivalent volume
of fossil natural gas that would otherwise be consumed. The development therefore
contributes to reducing greenhouse gas emissions rather than increasing them and is
directly aligned with objectives in the Climate Action Plan 2025 (CAP25) and the National
Biomethane Strategy (2024), helping to decarbonise hard to abate sectors such as heat,
transport and agriculture.
The suggestion that biomethane should only be supplied to local off-grid industrial users
is unnecessarily restrictive and would signiflcantly limit the environmental beneflts of the
project. Grid injection allows renewable gas produced at the facility to be used wherever
demand exists, maximising fossil fuel displacement and improving overall energy system
fiexibility and security.
Wetland Proximity
An Taisce: It is noted that the proposed soil relocation area, which is to be converted into
improved grassland, is adjacent to an area of scrub and wetland which is functionally
linked with the Drumintin wetland (site code: MIW_MN610), as designated within the
Wetlands Survey Ireland mapping tool. While an ecological survey is required for this site,
it is noted as likely containing fen, reed swamp, scrub and wet grassland habitat which is
likely to support species and habitats of ecological interest.
The retention of such areas is increasingly crucial in the context of a deteriorating
biodiversity emergency due to their provisioning of essential ecosystem services such as
fiood attenuation, wildlife habitat provisioning, carbon sequestration, soil health etc.
Consequently, it should be ensured that the proposal does not introduce adverse
impacts upon the ecological integrity of this locally important wetland site, including the
functionally linked scrubland which adjoins the soil relocation area.
Section 59(B) of the Wildlife (Amendment) Act 2023 provides for public bodies to have
regard to plans, programmes or strategies concerning the promotion of biodiversity
conservation and the objectives/targets of the most recent National Biodiversity Action
Plan (NBAP) in the performance of its functions. It is submitted that this applies to the RECEIVED: 28/08/2026
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Council’s decision-making function when assessing the subject proposal, which
contains biodiversity conservation considerations.
Response
The speciflc concern raised by An Taisce insofar as it relates to the proposed reproflling
of the Soil Relocation Area no longer arises, as that element has been removed from the
Proposed Development.
Notwithstanding its removal, the Applicant commissioned Hydro Environmental
Services (HES) to undertake a speciflc hydrological and hydrogeological assessment of
the retained Renewable Biogas Plant site and to establish whether construction or
operation of the revised Proposed Development has the potential to affect the
hydrological or hydrogeological regime of nearby wetland areas. The assessment was
prepared expressly in the context of the revised proposal and omission of the Soil
Relocation Area.
The HES assessment concluded that, following removal of the Soil Relocation Area, there
is no identifled hydrogeological linkage by which the revised Proposed Development
would alter the hydrological balance of Drumintin Wetland or any other wetland feature
in the surrounding area. The assessment further concludes that the Proposed
Development will not result in deterioration of any Water Framework Directive quality
element or compromise achievement of the relevant WFD objectives.
The HES report is enclosed with the Further Information response and should be read in
conjunction with the revised Chapter 10 – Water (Hydrology and Hydrogeology) and the
updated Water Framework Directive Assessment.
Greenhouse Gas Savings & Traffic Impact
An Taisce: It is noted from Chapter 1 of the EIAR (p. 5) that the applicant justifles the
proposal by referring to greenhouse gas emissions (GHG) savings “of up to 42,000 tCO2e
per year, equivalent to taking approximately 9,000 cars off public roads annually.”
However, it should be assessed whether additional Heavy Goods Vehicle (HGV)
movements arising from the subject proposal to transport waste inputs and process
outputs do not contradict these claimed emissions beneflts. A comparative assessment
of emissions implications in this respect would be a beneflcial exercise.
Based on our calculations of the applicant’s total Average Annual Trips as outlined in
Table 2-6 (EIAR CH.1, p. 39), this equates to 7,634 trips. It should be clarifled whether this
total includes the trip associated with vehicles exiting the compound after delivery and
whether the plant will be operational for 365 days of the year, which would bring the total
Average Annual Trips to 9,855. Furthermore, the issue of HGV traffic is likely to be of
concern to the local community, necessitating a robust Traffic Impact Assessment and RECEIVED: 28/08/2026
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Road Safety Audit to ensure that the local road network can facilitate additional HGV
traffic and that community amenity and safety is not compromised.
Response - GHGs
Emissions associated with the transport of feedstocks to the Renewable Biogas Plant and
the transport of products from the facility have been expressly included within the
greenhouse gas assessment presented in Chapter 14 Climate of the EIAR. The
assessment therefore does not calculate the greenhouse gas beneflt of the Proposed
Development while excluding the emissions associated with its operational HGV traffic.
Table 14-7 of the EIAR quantifles operational transport emissions, including HGV
movements associated with feedstock, digestate and CO₂, at approximately 265 tCO₂e
per annum under Scenario 1 and 281 tCO₂e per annum under Scenario 2. These
emissions form part of the overall operational greenhouse gas emissions assessed for
the Proposed Development.
The Climate assessment also quantifles the greenhouse gas offsets associated with
operation of the Proposed Development, including displacement of fossil natural gas by
renewable biomethane, replacement of more carbon-intensive fertiliser products,
avoidance of emissions associated with the existing management of poultry manure, and
beneflcial capture and use of biogenic CO₂. The total annual emissions offsets are
assessed at approximately 50,635 tCO₂e under Scenario 1 and 56,857 tCO₂e under
Scenario 2.
After accounting for the emissions arising from construction and operation of the
Proposed Development, including operational transport, the resulting net annual
greenhouse gas balance is approximately -35,751 tCO₂e under Scenario 1 and -42,473
tCO₂e under Scenario 2. The reference in the EIAR to greenhouse gas savings of up to
approximately 42,000 tCO₂e per annum therefore refiects the net assessment and does
not exclude the emissions associated with HGV movements to and from the facility.
Accordingly, the operational transport required to serve the facility has been incorporated
into the Climate assessment. The Climate assessment concludes that the overall
greenhouse gas effect is direct, long-term, positive and slight, and not signiflcant.
Traffic Impact
A robust Traffic and Transport Assessment (EIAR Chapter 6) and Road Safety Audit have
been submitted as part of the Application and should be read in conjunction with this
response.
The assessment considers the capacity and safety of the receiving road network. The
Proposed Development includes a new access from the L2280 together with
improvement works to the L2280 and its junction with the R189. Swept-path analysis and RECEIVED: 28/08/2026
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a Road Safety Audit have been undertaken. Following removal of the Soil Relocation Area,
no development traffic will use the L2320 fleld access.
Figures provided in relation to Average Annual Trips include for the delivery and collection
of materials to and from the site. For clarity, each HGV vehicle visit to the facility
comprises an arrival at and subsequent departure from the site. The forecast HGV flgures
are based on vehicles entering the site and the corresponding outward movement.
There will be no deliveries or collections on Sundays or bank holidays, which leaves a
total of 303 delivery / collection days across the year. Based on recorded vehicle
movement data at the Applicant’s operation biogas site in Ballymena, Co. Antrim, it is
reasonably expected that in terms of materials import and export Saturdays are not
typically as busy as weekdays. For the purposes of the assessment of traffic, it is
assumed that Saturday counts as a half day, in which case the Average Annual Trip
numbers are based on 277 days per year.
Having regard to the predicted operational traffic associated with the Proposed
Development, together with the location, scale and traffic-generating characteristics of
other existing and permitted developments considered in the cumulative assessment,
the combined traffic demand is not predicted to result in a signiflcant cumulative effect
on the receiving road network. Accordingly, the cumulative residual operational traffic
effect is assessed as not signiflcant.
RECEIVED: 28/08/2026