Sample Letters of Objection to Biodigester Input Increase

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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

Building on Flood Zone

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Village Fears Future Flooding

 The latest planning proposals for the village of Clyst St Mary from the Development Agents, Jones Lang LaSalle, (who represent the previous and present linked companies of Friends Provident/ Friends Life/F & C Reit/BMO Real Estate and Aviva) have been submitted to East Devon District Council for consideration under Planning Application 16/2460/MOUT. However, the development proposals include 150 residential dwellings plus employment and community units on areas of the decommissioned Aviva Insurance headquarters at Winslade Park that lie within a flood zone!

The Developers recently held a Public Consultation in the Clyst St Mary Village Hall displaying their future plans for consideration and requesting comments by the residents to enable these to be incorporated into their overall masterplan. The photographs below were forwarded to them showing the extensive flooding that was experienced in this area when the Grindle Brook burst its banks at this time last year on 30th December 2015 and it was emphasised that certain zones, in this vicinity, flood frequently and these areas were, therefore, not considered to be suitable for residential, workplace or community development.

The link below identifies the current flood risk and shows the vulnerability of the Winslade Park site, proving that substantial future flood defences are essential, although the Environment Agency website states that “flood defences do not completely remove the chance of flooding and can fail in extreme weather conditions.”

https://flood-warning-information.service.gov.uk/long-term-flood-risk/map?easting=297816&northing=90559&address=100040161688

 

Sadly, the Developers have chosen not to take local representations from the Public Consultation into consideration and have continued with their development proposals on areas of land subject to High Risk (Flood Zone 3) classification by the Environment Agency.

At present the East Devon Villages Plan 2016 is also in the process of Public Consultation to consider new built-up area boundaries for certain villages (including Clyst St Mary), with a Planning Inspector determining where such future development boundaries should be defined. However, the Developers’ inappropriate planning applications for development on flood plains at Winslade Park could now be considered for a decision by the East Devon District Council’s Development Management Committee before the residents of Clyst St Mary have the opportunity to put forward their comments on this site to the Government Inspector. This seems to be totally undemocratic and certainly not fully representational, being not in accordance with the main principles directing the devolution of decision-making to local people in the Localism Act.

Mark Wilson is the Group Chief Executive of Aviva. This huge company is one of the linked companies associated with this proposed development at Winslade Park. Wilson was named in 2016 as one of Britain’s 500 most influential people who have made a difference to British society. He was noted for finalising the £5.6 billion acquisition of Friends Life with the resulting merger turning Aviva into one of the UK’s largest investors managing £300 billion plus assets.

Writing in The Telegraph in 2014, Mark Wilson emphasised that there should be a halt on building on “defenceless” flood plains. He stated that “As a nation we need to build more homes, but the cost of development must include the cost of defences.” His mantra continued “Let’s be crystal clear: no defences, no development. We can’t stop the weather, but we can act in unison to minimise the impact of extreme events and we know that the threat is only going to increase, with scientists predicting greater flood frequency and extreme weather as a result of climate change. Although the current focus for us all is coastal and river flooding, surface water flooding is a major concern. More homes, driveways and car parks all contribute to more water flowing into the system, and flowing quickly.”

He acknowledged that flooding is one of the most traumatic events that any householder or business can face, with families forced out of their homes, valuable and much-loved possessions being ruined and businesses struggling to trade. He was aware that it can be many months before the drying-out process is completed and subsequent repairs can commence and that being the Chief Executive of Aviva, the UK’s largest insurers, he understood the emotional cost, trauma and feeling of vulnerability that comes with flooding.

Even with the Flood Re scheme which guarantees affordable insurance for households in flood-prone areas, surely it would be prudent not to create the problem by developing on areas at risk of flooding, thus sparing the necessity for future flood insurance claims on those same areas. Specific localities of the village of Clyst St Mary have a history of flooding with the images below showing the areas outside The Half Moon public house and Frog Lane in 1946.

Consequently, the residents of Clyst St Mary applaud the views of Mark Wilson, Group Chief Executive of Aviva, and hope that his strong opinions on flooding and huge influence will have a direct effect on the development proposals by the Insurance Group incorporating Aviva for the residential, workplace and community areas at Winslade Park, Clyst St Mary that lie within a flood zone!

Let’s be crystal clear: no defences, no development

flood-zones

Friends Provident High Risk Flood Zones

Photographs of recent flooding

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