Sleaford Town Council Response: Commercial Anaerobic Digestor Plant at Holdingham.

Further to my Blog dated 3rd July 2017 I can report that the Sleaford Town Council has submitted its reply to the proposal.

 I can confirm that we have based our advice note on a review of the following documents:

• Planning Application Supporting Information (The Greenspan Agency, 9 May 2017);
• Odour Management Plan (The Greenspan Agency, 5 July 2017);
• Consultation responses available on the County Council’s online portal at 18 July 2017.

Regard is also had to the planning history of this site and our previous letter of advice to the Town Council dated 24 June 2014.

As with all applications of this nature the applicant will be expected to demonstrate that the proposals will have no adverse environmental impacts and / or lead to the loss of residential amenity. It is our professional opinion that the information to submitted to date is ‘thin on the ground’ and leaves a number of fundamental issues unanswered. Whilst we acknowledge that the applicant has provided an additional Odour Management Plan (dated 5 July 2017) we would recommend that the Town Council make the following observations.

Vehicle Movements

One of our principal concern relates to a general lack of information in relation to vehicle movements and traffic generation. Whilst is accepted that the junction serving the site may be operating under design capacity – as stated by the applicant in Para 7.2 of the Planning Application Supporting Information document – little information has been provided in relation to the exact nature of the anticipated highway movements. The applicant states that “vehicle movements to and from the site are not expected to change as a consequence of this current application to allow a broader range of feedstocks” yet no evidence is provided to substantiate this claim. Even if this assertion is accepted, the timings and frequency of vehicle movements needs to be considered. For example, will movements be dispersed throughout the day or will movements be concentrated in peak am and pm periods? We are aware that the highways authority have no raised no objection to the development (19 June), however, we would maintain that it is not possible to fully assess the likely highways impact of the change in operation practices without detailed information provided by the applicant. We would therefore recommend that the Town Council request that a Transport Assessment is provided by the applicant and that the Town Council reserves the right to make further representations on the content of that particular document.

Odour Management

It is acknowledged that the applicant has sought to provide further information in the form of an Odour Management Plan dated 5 July. That document states that the applicant has sought to remove condition no. 7 of the previous planning permission states the following:

No development shall commence until an odour management plan has been submitted to and approved in writing by the District Planning Authority. The plan shall detail how, where and when odour from the development hereby permitted will be measured post-operation, who will be responsible for this, the method of assessing the results of odour measurement  and any required  mitigation measures.. The odour management plan shall include a procedure for recording and addressing any odour complaints received. Thereafter the approved plan shall be implemented and maintained in perpetuity.                                   

                               

Reason: In the interests of reducing odour pollution to protect the amenity of the area in accordance with saved Policy C17 of the Local Plan

The applicant argues that the condition is not necessary as safeguards in terms of odour are in place through separate environmental permits which fall outside of the Town and Country Planning Acts. However, we would advise that the Town Council strongly contest the removal of such a condition as it removes the ability of the Council’s enforcement team to take action should the requirements of the condition and approved odour management plan be breached.

Turning to the current application, we have concerns about the short term nature of the odour management plan which appears to be overly dismissive of potential odours which may emerge outside the first 12 months of operation (see Para 2.2).  We are also aware that Leasingham and Roxholme Parish Council have expressed concerns in relation to the validity of some of the conclusions reached in that report. At the time of writing there does not appear to be any consultation response from the following consultees:

• Environment Agency;
• Environmental Health Officer; and,
• LCC Public Health Officer;

As the Odour Management Plan is a specialist technical document its content can realistically only be adequately understood (and challenged if necessary) by a suitably qualified individual and we would suggest that the Town Council ensure that comments are received by all the 3 of the above consultees before the application is determined – particularly the Environment Agency.