Sample Letters of Objection to Biodigester Input Increase

18/2173/VAR  Variation of conditions 2, 5, 7 and 10 of planning permission 17/0650/VAR to allow increase annual tonnage of crop input from 26,537 to 66,000 tonnes and increase annual tonnage of digestate exported from the site from 21,354 to 56,000 tonnes and vary wording of Odour Management Plan – Enfield Farm Biodigester Oil Mill Lane Clyst St Mary EX5 1AF

The previously approved variation (17/0650/VAR) in October 2017 to treble the number of farms for sourcing crops to Enfield and exporting end-products from 8 to 24 farms over excessively long distances was purportedly to defend against crop failure and not to support a systematic expansion of the high-income energy output. 


This Variation application should be viewed and considered as a parallel application with Application 18/2437/MFUL – Installation of a roof and roller shutter door to existing storage clamp; installation of dome to collect residual gas and installation of digestate processor unit (which has been submitted separately by the Applicants) because the increased infrastructure application results from the increased tonnage application in this variation.


Since 2014 the Applicants have pursued expansion with continuous individual variations (some retrospective) which have camouflaged the overall cumulative growth of this facility and these have already resulted in a substantially sizeable development that now has the capacity to produce over double the approved energy output and although some evolution is supportable, over-development in this village near residential areas is neither acceptable nor sustainable.
Everyone should support the future production of sustainable, environmentally friendly energy production – but approving a small on-farm Anaerobic Digester in Clyst St Mary is entirely inconsistent with approving a huge industrial-sized one and equates to an application for a minor residential extension mushrooming into a large supermarket!
The original approved vision for an environmentally-friendly small, sustainable on-farm digester at Enfield has become lost in the master plan to create a lucrative energy output facility because the necessary massive investment needs to reap huge profits but this is not the correct location for such an overlarge industrial-sized development.


Conditions limiting site size, infrastructure, tonnage, transportation and output have been imposed on Enfield anaerobic digester applications to protect the amenities of local residents and control over-development.
This development has caused local people much distress since 2014, with detrimental odours, noise, dust and traffic issues which, as evidenced by the recent objections, are still occurring. Substantially increasing the tonnage of crop input and digestate export will exacerbate problems previously experienced from unacceptable practices which East Devon’s Environmental Department have worked tirelessly and doggedly to rectify and Conditions 5, 7 and 10 of Application 17/0650/VAR were imposed in October 2017 to specifically protect the amenities of local residents and must consequently not be waived.
This latest variation application now seeks to more than double crop imports from 26,537 to 66,000 tonnes per annum, to increase imported farm manure and dairy by-products plus the doubling of Enfield pig slurry with an increase in annual exports from the site from 21,354 to 56,000 tonnes. Furthermore to approve daily additional tractor and trailer movements on the A376 between Clyst St Mary and an Exmouth lagoon during non-harvest winter months in an already heavily trafficked area causes great concerns from local people, especially when residents already spend long, arduous journeys in low gear behind slow moving tractors and trailers over prolonged distances.


Detrimental vehicular air pollution on the A376, A3052 and around the Clyst St Mary area, has been the subject of recent monitoring and East Devon’s Strategic Planning Committee already recognises that “Junctions 29 and 30 of the M5 and the Clyst St Mary roundabout are at capacity and will be significant constraints on future development in much of East Devon” making the Applicants’ comments that these proposed increases ‘have limited impact on the highway network capacity and safety’ acutely controversial. Highways England stated last year that “the development can only be considered to be sustainable if feedstock sources and digestate deliveries continue to be focused on the local area.” 


The Government recognises that many anaerobic digesters are using mainly crop-based energy methods instead of the original accepted concept of waste to energy and believe that these practices could ultimately have a negative effect on future national farming and food production costs. Hauling over long distances is not sustainable and problematic; growing predominantly maize causes soil erosion, pollution of water courses and flooding and detrimental odour, noise and traffic near residential areas is unacceptable making any further large- scale development expansions of Enfield inappropriate and insupportable.

Editable Version of Letter of Objection in Word Format

18/2437/MFUL  Installation of a roof and roller shutter door to existing storage clamp; installation of dome to collect residual gas and installation of digestate processor unit – Enfield Farm Biodigester Oil Mill Lane Clyst St Mary EX5 1AF

Although this application appears solely to be adding a roof to an existing storage clamp, installing a dome on an existing digestate tank and building a  new digestate processing facility, it must be viewed and considered as a parallel application with Application 18/2173/VAR (which has been submitted separately by the Applicants) to double crop imports from 26,537 to 66,000 tonnes per annum, increase imported farm manure and dairy by-products and double the pig slurry, which will in turn increase the annual Enfield exports from 21,354 to 56,000 tonnes because the increases in tonnage are inextricably linked to this application for the expansion of infrastructure at Enfield to accommodate such vast tonnage growth. Furthermore, there is uncertainty whether this increased infrastructure has already been built retrospectively before planning permission has been granted.


Since 2014 the Applicants have systematically pursued expansion and there is no doubt that, at present, the Enfield Biodigester has been developed to produce more than double the approved energy output.
The gradual growth over 4 years has been disguised by continuous individual planning applications for extensions which singly do not represent large-scale development. Consequently, by a steady drip-drip-drip process of separate expansion applications (which camouflage the overall cumulative growth), Enfield Anaerobic Digester has materialised into an unsustainable, vast development in this neighbourhood. Although some evolution is supportable, such over-development in this village, near residential areas, is neither acceptable nor sustainable.


Future environmentally-friendly energy production is obviously a goal that needs to be achieved – but approving a planning application for a small on-farm Anaerobic Digester at Enfield in Clyst St Mary in 2014 is definitely at variance with now approving a massive industrial-sized development of this magnitude in this particular locality!
These latest proposals include partial roofing on a 104-metre long silage clamp, a 9 metre digestate processing facility but more worryingly an additional new domed structure reaching 12 metres high on an existing digestate tank. Enfield Anaerobic Digester is sited in an elevated location with existing large structures viewable from far afield, so another dome reaching 12 metres high will exacerbate the detrimental effects on the landscape amenity, especially since much of the previous conditioned mitigation landscaping (including native woodland, Devon hedges etc) has yet to be planted.
Such increases do not comply with the Conditions limiting site size, infrastructure, tonnage, transportation and output which have previously been imposed by planners specifically to protect the amenities of local residents and control over-development.


In 2014 the Applicants stated: –
“Enfield was selected owing to its close proximity to where the pig slurry is produced and its closeness to land onto which the digestate would be spread; this was an on-farm AD to service the needs of the adjacent pig farm where the same owner would grow the crops required to mix with the slurry to maximise gas output” but this environmentally-friendly vision has since become lost in the master plan for Enfield to create a very large high-income energy output facility because such massive investment needs to reap huge profits.


Since 2014 this development has caused local residents problems with detrimental odours, noise, dust  and traffic issues and from the objections attached to both these applications (e.g. “What once was a lovely place to live has now been ruined by Enfield farm”), residents living nearby in Oil Mill Lane are still being detrimentally affected by odour, noise, dust and traffic issues which are blighting their day-to-day lives and continue throughout the night (1a.m.), when time restrictions for work practices were restricted by planners. Such substantial expansion will only exacerbate previous problems experienced throughout Clyst St Mary from unacceptable practices that East Devon’s Environmental Department have worked tirelessly and doggedly to rectify.

Residents accept normal agricultural practices in their locality which may generate some odours, noise and transport from time to time – but this anaerobic digester at Enfield has now evolved into a monster that is difficult to control and by substantially increasing quantities of crops, farm manure, dairy by-products, pig slurry and infrastructure, nuisance odours, noise and traffic problems will also potentially increase.
The disadvantages of further expansion weigh heavily against both submitted applications. Their procedures are too heavily crop-based and contrary to the concept of waste to energy on which the 2014 application was approved. Large-scale maize harvesting for energy production could ultimately have a negative effect on future national farming and food production costs and can cause soil erosion, pollution of water courses and flooding. Feedstock sources and digestate deliveries are not focused on the local area and are hauled over unacceptable distances causing traffic congestion and detrimental vehicular air pollution from slow moving tractors and trailers on highly trafficked highway networks – making this application unsustainable, inappropriate, unpopular and insupportable.

Editable Letter of Objection in Word Format

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