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14/0858/MFUL | Construction of agricultural anaerobic digester plant for production of renewable energy | Enfield Farm Oil Mill Lane Clyst St Mary Exeter EX5 1AF
  • Total Consulted: 19
  • Comments Received: 6
  • Objections: 4
  • Supporting: 1

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Mr & Mrs Trout (Objects)

Comment submitted date: Thu 23 Jul 2015

see scanned letter and attachment dated 18.07.2015 under documents

Mr E Tommans-Porter (Objects)

Comment submitted date: Tue 21 Jul 2015

see scanned letter dated 20.07.2015 under documents

Mr Eric Trout (Objects)

Comment submitted date: Wed 16 Jul 2014

West Team East Devon Planning Reference: 14/0858/MFUL

From the Owners of Linden Lea, Old Sidmouth Road, Clyst St Mary, Devon, EX5 1DL. Unfortunately we have only just become aware of the scale of this development and the potential risks to human life and adjoining properties

Explosion element Our main objection is the possible explosion element to the proposal. Linden Lea, a Grade II listed cottage, in Old Sidmouth Road, is currently rented to our eldest son who has his teenage son and daughter living with him. The thought of them being blown to kingdom come is untenable.

Drainage We also suspect this would add to the current drainage problems ┐ there is continual water seepage across the road in the vicinity of the entrance to Dartline Coaches and despite the Council clearing the drains regularly there is never any improvement. When it rains hard the rain runs down from the area of the current storage tank at Enfield and floods the road

Watercourse We have very real concerns regarding seepage into the watercourse and subsequent contamination of our well, the level of which is only 0.5 metres below ground level and that┐s at this time of the year when we have had a significant dry spell. As soon as it rains the pumps are in action.

Danger of gas from slurry We think the location on top of the hill is totally inappropriate and is in direct line of fire with our cottage. If there was a gas escape with gas being heavier than air it will roll down the hill straight onto our property and the adjoining A3057 with the possible ignition risks to this gas cloud from the coach park and passing motorists. Goodbye cottage. Slurry gases do kill. Six people in Northern Ireland have died in the last two years and there have been many serious incidents where others have been overcome by gas released from slurry during mixing. Hundreds of animals have also been killed in similar circumstances. Although the UK seem rather coy at releasing their fatalities; more information is available from the Health and Safety Executive.

Fire potential What is the fire potential? None of your documents appear to have involved Devon & Somerset Fire and Rescue Service. Silage has an uncanny habit of self-ignition when left, see the European Guideline CFPA (Confederation of Fire Protection Associations)-E-Guideline-No-31-2013-F, which is a guide for farmers with regard to the storage of silage.

Residue from process Once the process is complete what is happening to the residue while it waits for disposal? If, heaven forbid, this development did go ahead and there was an accident ┐ would we be looking at a modern-day Aberfan?

Good idea ┐ totally wrong place.

Diana and Eric Trout

22 Parkfield Road
Devon, EX3 0DR

Tel: 01392 669299
Mob: 07778 765816 (Eric)
Mob: 07780 844987 (Diana)

cc Mr M Howe, Clyst Valley Parish Council.

T C Adams (Objects)

Comment submitted date: Mon 02 Jun 2014

I object to this application on a number of grounds explained below:-

Visual Appearance in open countryside

a) The Landscape and Visual Assessment accompanying the application very greatly underestimates the impact. This so discredits the report as to render it grossly misleading. It's author has been very selective in choice of viewpoints to analyse, by excluding, for example, views from two stretches of public highways, which I call viewpoints (i) and (2) as follows:

Viewpoint (i) an approximate 150m length of the A3052 Sidmouth Road (Eastbound) some 100m - 250m) west of its junction with Oil Mill Lane and

Viewpoint (ii) an approximate length of Oil Mill Lane (NW bound) between Kenniford cross and the unnamed cul-de-sac to Shepherds Farm where the proposed structures will be directly ahead for all persons travelling NWestward (ie from Woodbury Salterton).
From those viewpoints all persons, walkers, cyclists, motor-cyclists, truck drivers, but mostly motorists, already have a significant view of the piggery slurry tank, but only just on their skyline, so visual impact would be very much worse if the proposed much larger and particularly higher structures are built.

The proposals would blot out such attractive distant skylines as Beacon Hill and Woodbury Common. This is very unfortunate, but then to replace them by huge, hilltop industrial structures is to be deplored, and contrary to countryside protection policies.

If the landscape expert has ignored these viewpoints how many more will become painfully obvious when the much larger plants are built?

b) Proposed hedge and tree planting

The piggery's existing tree screening has, over the years become partly effective in screening the existing structures. This screening is proposed to be removed to allow the development footprint to be substantially increased eastward, but with proposed tree and hedge planting after the new structures are built. This would not have any beneficial screening effect for very many years, probably some tens of years, in screening the new much larger and higher structures. Planting large trees would not help. They would not survive wind-throw in such a windy location, on the top of a hill, with very steep slopes, falling to west and south.

c) Scale

The scale is huge.

Although the applicants vaguely propose to lower the foundation levels by a few metres, the gasholder/gas storage dome is huge, of 45m diameter and 7.5 metres high, all sitting on top of a tank of the same or very similar dimensions. The other two digestate tanks are also very large being 30m and 32m diameter and 7m high. The sectional drawings use an assumed datum, not Ordnance Datum, so it is impossible to be precise. Neither does the Application show the existing piggery structures, to allow easy comparison.

The 1:2,500 OS plan (blown up copy attached) has contours at 5m intervals which show the site to comprise a hilltop, with top between 25m and 30m. Even if a few metres depth of soil/strata were to be removed, as proposed, the base level would still be somewhere close to 25m AOD. With a proposed overall structure height of 15m the dome-top would be at about 40m AOD. This compares to the nearest parts of Oil Mill Lane (to the S and W of the dome) at below 10m AOD. This gives a difference of about 30m in level. The distance laterally is only between 100m and 300m from the whole 700m length of Oil Mill Lane between its junction with the A3052 and the bridge over the Grindle Brook.

Similarly at the identified viewing points (i) the carriage way level is around 20m AOD, giving a difference of about 20m higher; and at viewpoint (ii) a similar level.

In a generally gently sloping topography locally (except for this hillock the piggery and proposed site sits upon) this very steep angle of inclination will make these views of the proposed plant appear very high and dominating. Overall the proposal would vastly increase the size, scale and visual impact compared to the existing structures, which are already somewhat prominent.

d) Cladding Material

I cannot find much detail on this in the application. The existing slurry tank of the piggery is all one colour, a very uniform and "permanent" dark green, which is good in a countryside location. I say permanent in that it appears to be coated with a thin glass layer, which preserves the steel structure from visual deterioration for many tens of years. It appears this excellent system is not proposed. More information is required to judge how more striking the impact visually will be from colour (or more likely colours), and reflectivity (reflection of sunlight), of different proposed surfaces might have in making even worse the visual impact.

e) Gasflare

At night this would make a very strong visual impact, and would contribute to the industrialisation of this rural area so prominent to the many thousands of users each day using the A3052. It would be visible over a large area.

To summarise so far: This is not a suitable location for such substantially visible industrialisation.

I have concern about other aspects but will outline these more briefly below:-

f) Safety

A hilltop location with steep adjacent land to the south and west with several dwellings very close at the foot of that slope, at generally about 10m lower elevations, seems to me to be inviting disaster. In the event of a categoric failure, eg an explosion the 1m high safety barrier around the site may not be able to hold back the 10,000+ cubic metres/tonnes of slurry, possibly the similar quantity of silage sludge, if the 3,000m3 of gas, all to be stored at the site, With up to 2 dwellings within 80m, 4 within 100m, and 13 with 150m of the site, this does not seem to be a wise location in view of the risk of so many humans, so close.

The other aspects that need consideration are:

g) Noise

Especially the hammer mill. Also the conversion of gas to electricity involves very large engines which would need very effective sound insulation. Has a full noise assessment been undertaken?.

h) Smells

The proposal to maintain a small piggery alongside will make identification of source of smell difficult, if not impossible. This may cause considerable difficulties for the EA or EDDC public health staff in controlling smell nuisance. If source cannot attributed how can inspectors or prosecutors deal with it.

i) Spillage

The access ramp (not adequately detailed in the application) must be very steep (and very close to a dwelling). It may be too steep to meet road safety standards.

Presumably it will operate continuously 24/7. Only one operative for the whole site is proposed.

j) Need and Feed Supply

This is a very complex subject. Extensive areas of green crops will have to be grown, and stored, to supply a balanced feed to the plant. The process needs a full and steady supply of organic matter to operate economically. Using animal waste is a minor element.

With several under-utilised similar anaerobic digesters nearby (eg Willand) and a prospective similar plant very nearby, the case for need is suspect.

k) Traffic

The traffic numbers look very suspect.

Finally, please refuse this application.

Dr Mark van der Giezen (Neutral)

Comment submitted date: Wed 21 May 2014

Although I am in favour of sustainability initiatives such as the proposed anaerobic digester at Enfield Farm, I would like to raise some issues that I would like you to take into account during your consideration of this application.

1. Traffic.
a. Although the application provides a detailed traffic assessment, the figures and calculation provided are unnecessary complicated and perhaps flattering regarding the consequences of the proposed development. For example, current traffic is calculated on a 5-day week basis while planned traffic is based on a 6-day week. Obviously, this calculation gives an inflated current traffic volume versus a deflated planned traffic volume.
b. Although at a recent Parish Council meeting the owner mentioned that the site currently houses 3,000 pigs, this has not been the case recently as far as the documentation suggests (see Planning Support Statement, page 3, point 10 which clearly states that since 2011 the site did not operate as a piggery). Neighbours agree that this is indeed the case. Only recently has a typical odour of a piggery become noticeable. I only lived close to the site for about two years now but considering my property is situated 500 m upwind of the site, I had expected to be able to smell a piggery more often so I doubt whether the statement in the Environmental Assessment Review (page 6, point 29) is actually correct. When living downwind of Kenniford Farm for five years, the smell was more obvious than that what is coming from Enfield Farm for the last few years. When asking several neighbours, they all agreed. So, the comparison of current versus planned traffic might not be totally justified considering that up until recently, there was very little traffic to the site.
c. Similarly, the comparisons of the current existing application regarding the use for light industrial use with possible 84 vehicle movements compared to only 20 trips for the digester are misleading. The 84 vehicle movements for light industrial use would likely constitute motorcars, vans and the occasional lorry. The digester though would attract large lorries and tractors and it is clear that the latter are more disruptive when it comes to noise and possible obstructing country lanes than the smaller vehicles. In addition, that comparison is rather hypothetical as the owner apparently did not decide to proceed with using the facility for light industrial use.
d. Although I would expect most deliveries to arrive via Sidmouth Road, visibility from Oilmill Lane onto the site is rather limited. An increase of large vehicles will not improve safety at the tight northern end of Oilmill Lane. In addition, the planned expansion of Woodbury Salterton and the rugby fields have not been taking into consideration in this application as far as I could ascertain from the provided documentation. This would most likely lead to rather high traffic volumes on the mainly single file northern end of Oilmill Lane.
e. During the presentation on Monday the 12th of May, the gentleman from Greener For Life said that deliveries would take place during working days from 8:00-18:00. However, the Planning Support Statement (page 6, point 31) clearly mentions that nightly deliveries will happen at possibly 20 days per year. When I asked this question, the gentleman from Greener For Life was rather evasive which suggests I am correct that nightly deliveries will happen and these will be rather disruptive for local residents. In addition, the Planning Application (point 20) clearly asks for permission to be open 365 days per year from 7:00-18:00. So, the suggestion that this site is only open during the day from Monday to Saturday is misleading to say the least.

2. Odour.
a. As mentioned above (1b), it is questionable if the current odour nuisance scenario is correct, as up until very recently, there was very rarely any smell to be noticed. Neighbours all wonder how long the piggery has been operating with 3,000 pigs and wonder if that has recently started again. This would be in agreement with the statement in Planning Support Statement, page 3, point 10 where it says that ┐┐the farming business has now had to return to raising pigs at Enfield Farm┐┐. So, ┐current┐ versus predicted odour nuisance can not be used to say the digester would smell less than the piggery.
b. Products from anaerobic digesters are indeed virtually odourless. However, it is the material that enters the digester that causes odour pollution. This is especially true if food waste is used which we were told was not the case at the Parish Council meeting and apparently, the digester would supposedly not be suitable to be used for food waste according to the gentleman from Greener For Life. However, looking at the specifications at the website from the company that produces the Biogest PowerRing, it seems that this digester can take all material for processing ( I would like to ask the Council to strongly state that this site should never be used for food waste processing and solely for agricultural material. Storage of food waste will cause unacceptable levels of odour pollution.
c. The over 16,000 tonnes of maize silage (see point 1b above) will be stored on site using silage clamps (Odour Management Plan page 2). Maize silage produces indeed a typical countryside smell as the gentleman from Greener for Life mentioned during the Council meeting and I do not object to this smell. However, over 16,000 tonnes of maize silage can feed around 1,000 cows for a year. As not many farmers have that number of cattle, the suggestion that this is ┐just countryside smell┐ is perhaps somewhat misleading.

3. Capacity.
a. The application is for a 2 MW anaerobic digester facility. Based on information from Biogest, this is their largest anaerobic digestor. However, neither from their information nor the application, it is clear if the currently proposed 28,537 tonnes of feed stock is the maximum capacity of the digester. It would be prudent to inquire whether the digester has a larger capacity intake than what is currently proposed as, once permission has been granted, it would be rather easy to increase deliveries to get the maximum benefit out of this facility. However, this would lead to increased numbers of large vehicle movements and additional disruption.

As mentioned earlier, I am in favour to introduce more sustainable facilities and anaerobic digesters are one of the great solutions to get rid of agricultural waste and produce additional energy. As an anaerobic biochemist I know that these facilities, if managed properly and when using agricultural waste, will produce little nuisance. However, as might be clear from the above, there are several issues that need clarification before an informed decision can be made and I would appreciate if the East Devon County Council could take these issues into account when deliberating the merits of this application.

Mr stephen taylor (Supports)

Comment submitted date: Mon 12 May 2014

first of all i am very interested in the fact that the amount of lorrys going up to this construtions.They will be coming out onto a lane which is very busy now.You already have coaches from dartline you will soon have traffic from Exeter rugby trainning and now this. Can some one tell me if a fie engine ,ambulance or police had to get up oil mill lane how do they
2: The smell from this will be very bad i run a holiday cottage would you want to stay there with traffic like this and smell

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