Great Bowden Anaerobic Digestor – template for comments to the County Council

Traffic

  • The Transport Statement as part of the application states that the development would generate a maximum of 52 two-way HGV movements per day (26 in each direction) during the busiest 30 days of the year. These would be spread throughout the working day with a maximum of 4 two-way HGV movements per hour. This appears to assume 13 hours of continual deliveries, with no peaks or troughs, and each load unloaded with no delays or snags every half hour.

 

  • There are concerns that many of the materials (straw, maize etc) that are feedstuffs for the proposed plant are typically transported by tractors and trailers, rather than HGVs, and that this is what would be likely to happen in practice, generating even more vehicle movements. A significant number of these deliveries will be lower speed loads.  Given that at this point the A6 is only one lane in each direction, so these lower speed vehicles have the potential to trigger significant tailbacks and dangerous overtaking.

 

  • Given the nature of these agricultural loads and the tight nature of the turn off the A6, the point where they turn in will require large loads to slow to a very low speed, causing further disruption on the A6.

 

  • Problems will be worse still on the single track Welham Lane, which has a significant number of dog walkers and other pedestrians from nearby.

 

  • In the case of recent planning application 20/01497/FUL, which proposed the erection of a light industrial building on a neighbouring site on Welham Lane, the Local Highway Authority advised refusal on the grounds that: “The applicant has failed to demonstrate that the impact of the development on the local highway will be mitigated and if permitted would lead to the intensification of use of Welham Lane, which is unsuitable in its width and design to cater for an increase in traffic, which could result in lengthy reversing manoeuvres not in the interests of highway safety, contrary to paragraphs 108 and 109 of the National Planning Policy Framework.”

 

  • Policy EMP2 (3) of the Great Bowden Neighbourhood Plan states that development should “Not generate severe levels of traffic movement”, and this application would.

 

Air quality and smells

  • The air quality assessment submitted alongside the application acknowledges that there will be smells from the plant, but that these are normal for the “wider area”.  It argues that: “With regard to odour, the main potential source of emissions will be associated with the loading of feedstock into the AD Plant. Agricultural odours, including those associated with livestock rearing, are likely to be characteristic of the wider area”.  In reality there is no activity producing smells on this scale nearby. 

 

  • Policy W6 of the Leicestershire Minerals and Waste Local Plan (2019) states that “Planning permission will be granted for waste facilities for anaerobic digestion, open air composting, and other forms of biological treatment outside of those areas set out in (i)-(iii) of Policy W4 where the proposal is an appropriate distance from any sensitive receptor.”

 

  • Policy DM2 states that: “Where appropriate, separation distances between a development and other land uses will be applied.'

 

  • This is not the case in this planning application, which is immediately adjacent to a number or residential properties; and where the majority of the population of the large village of Great Bowden (population around 1,500) are within 1,000m of the site.

 

  • Policy EMP2 (D) of the Great Bowden Neighbourhood Plan states that: “new development will be required to… Not increase noise levels, fumes, odour or other nuisance to an extent that they would unacceptably disturb occupants of near-by residential property;”

 

  • In other cases around the country where AD plants have been built near to people’s homes there have been reports of bad smells and poor air quality, despite proposes made during planning that this would not be the case. Examples include:

 

  • Wessex Water, Avonmouth (BBC, 15 September 2022)
  • Fernbrook Bio, Rothwell, Northamptonshire (BBC, 17 May 2023)
  • Farleigh Wallop, Hampshire, (Basingstoke Gazette, 13 February 2020)
  • Gelligaer in Caerphilly, (Wales Online, 23 September 2023)
  • Preston Farm, Stockton on Tees, (Gov.uk, 2 March 2023)
  • Wardley Biogas Plant, Jarrow, (Newcastle Chronicle, 10 July 2023)

 

Flooding and drainage

  • The application form for the proposed plant claims that the proposal will not increase the risk of flooding elsewhere and is not in an area at risk of flooding, although the separate landscape and visual statement notes that: “the application site and its immediate surroundings fall into Group 3, River Valley Floodplains, more specifically into 3A, Floodplain Valleys landscape character type.”

 

  • The neighbouring farm has previously experienced damage from surface water flooding.  The site currently comprises a large open area occupying around half of the site, which allows rain to soak away.  This will be replaced almost entirely with buildings, structures and hard standing. While the applicant proposes to capture some of this rainwater, it is unlikely to be able to capture all of it during intense rain, increasing the risk of runoff onto the neighbour’s property.

 

  • There are further concerns about the ownership of the drainage ditch between the site and the neighbouring farm.  The neighbours state that they have previously established ownership of this drainage ditch.  Despite this, the applicant shows this as belonging to the property they are making the application on.

 

Landscape and heritage impact

  • Policy DM5 of the Leicestershire Minerals and Waste Local Plan (2019) states that development will be supported where: “the proposal is well designed, contributes positively to the character and quality of the area in which it is to be located”.

 

  • Policy EMP2 (B) of the Great Bowden Neighbourhood Plan states that: “new development will be required to… Be of a size and scale not adversely affecting the character, infrastructure and environment of the village itself and the wider Plan area, including the countryside.”

 

  • In both cases the significant number of objections from nearby residents suggests that these tests are not met.

 

Ecology and biodiversity

 

  • The Great Bowden Borrow pit SSSI is just over 800 metres west from the site.

 

  • The preliminary Ecological Appraisal by Archer ecology (March 2023) makes a number of recommendations, not all of which appear to have been acted upon, even though the application is now asking for a determination, and some of the issues should be resolved before determination.  For example, it recommends that “reptile surveys are undertaken which would involve deploying artificial refuge material across the site to be checked on seven occasions during March to October, inclusive. Reptile activity is seasonally dependent with surveys being most effectively conducted during April, May and September and during suitable weather conditions.”

 

Safety

  • No industrial activity is without risk, and sites for the production of biogas would ideally be safely away from residential properties, which is not the case here, with homes within 100m of the site.

 

  • On 2 October 2023 A lightning strike at the Severn Trent Green Power (STGP) biogas facility in Cassington, Oxfordshire, caused a huge explosion and fire.

 

  • In 2014, a processing tower at an AD plant at Harper Adams University in Shropshire collapsed, spilling toxic slurry across the neighbouring countryside.

 

  • In 2017, when a container exploded at ADD firm Bio Dynamic in Nottingham, one worker lost his leg while another man was injured.