Summary of Objection
The proposed site down Foston Lane is located a mere 400m from the nearest dwelling and is close to and well within sight of three villages, Beeford, North Frodingham and the conservation area of Foston on the Wolds with its Grade II listed St Andrews Church. The lane is frequented by many walkers, dog walkers, cyclists and horse riders for its calm, rural setting.
2. Beeford as a Rural Service Centre
Beeford is a vibrant village with a Post Office, Shop, Butcher, Doctors Surgery, Veterinary Surgery, Public House, Chinese Restaurant and take away, Fish and chip shop, School and Community Centre and serves many satellite villages.
Development in a Service Centre is encouraged to retain and increase vibrancy, vitality and sustainability of a community. A Waste plant will have the opposite effect and is thus not compliant with what is set out in the Local Plan for the future of East Yorkshire
3. Businesses affected
Businesses in the area will be affected, a Leisure storage facility, a Caravan site and a Veterinary Practice being the closest to the proposed plant. Other businesses within Beeford and surrounding areas will also suffer.
During the summer months a lot of traffic destined for the East Coast travels through North Frodingham and Beeford, there are also bike and vintage car rallies which often pass through our villages, all will be encountering severely increased HGV traffic.
There are also the Caravan sites and local holiday rental properties in the area that will be affected.
5. Flood Risk
On 25th June 2007 Beeford and many outlying villages suffered the worst floods ever seen in the area. The land of the proposed site is prone to flooding, in fact trees were planted and a pond dug out to try and alleviate this problem. The risk of Pitwherry Drain overflowing onto the site is a distinct possibility as it runs along side the proposed plant.
The Applicants had a noise assessment carried out by Dynamic Response. Consultants employed by the NOW Group reviewed this report and made the following comments :
- Only two hours worth of background noise survey data had been collected at some undisclosed position somewhere near the closest existing residential dwelling (1 hour 22.00-23.00 on 12.11.15 and 1 hour 2.00-3.00 on 13.11.15).
- No conclusive information about noise emission characteristics of internal plant/equipment.
- Assumptions made on the likely nature of noise attenuation measures in terms of building design.
- No allowance has been include for gas flaring
- No consideration given to noise associated with traffic movements and from incidental activities on site
A further report was also carried out by a local resident as an expert in this field and showed that, based on her figures, levels highlighted the potential for the equipment to be considerably above background noise levels and therefore cause a significant adverse impact on resident amenity.
She also commented that no assessment had been carried out by the Applicants on traffic noise.
Low level down lighting will be used at the plant but will still be visible against the clear night skies especially from Foston on the Wolds as there is no street lighting.
Gas flaring from 10 mtr chimney will be a conspicuous and eye catching element of the development giving an adverse effect on the night sky and surrounding tranquil area.
The proposed site will be processing animal, food and fish waste, including liquid fish waste and although the Applicants had an odour assessment carried out it did not fully portray the effects these products will have, not only during transport and unloading but also in the digestion process and afterwards as digestate which is known to have a far more pungent smell that pig slurry. Many complaints have been made about odour from AD plants including Julie Walters in the Mail Newspaper on 27th March 2016.
Odour Impact reports from residences near existing Anaerobic Digester Plants :
Biofuel plant, Nr Plaistow, West Sussex – emits a stench so strong people ’can’t sit in their gardens’ (March 2016, as quoted by Julie Walters)
Fernbrook Bio, Rothwell, Northants - County Councillor says that plant should be shut as the smells are destroying the quality of life for residents living over half a mile away from the plant.
HL Foods, Lincolnshire - Fined £140,000 by the Environment Agency for the horrendous smells affecting the local area, which they say is similar to the stench of “dead rats”.
Biffa AD, Cannock - Fighting horrendous odours for a year and a half affecting residents over 800 metres away.
Shanks AD, Cumbernauld - A foul stench still remaining after upgrading its bio filter monitoring system.
AD Plant in Farrington, Lancashire – Application to extend its exhaust stacks from 39 feet to 82 feet, to try and improve the air quality for local residents
Cannington Bio Energy - Anaerobic digestion plant was built to process farm waste but, since 2011, has dealt with food from outside the county. Locals said the change in use had caused an odour described as a mixture of "dog's muck and burnt plastic".
Foston, Derbyshire - Environment Agency refused permit for AD plant applied for by Midland Pig Producers as they could not be satisfied that the activities can be undertaken without resulting in significant pollution of the environment due to odour which will result in offence to human senses and impair amenity and/or legitimate uses of the environment
9. Accidents / Incidents
36 biogas plant explosions or serious fires have been reported in the press since 2003. In addition there were 39 pollution incidents through valve or tank failures.
10. Traffic & Highways
The proposed site is located down a small country lane known as Foston Lane off the B1249. It has a number of blind bends, pinch points and high hedges making it totally unsuitable for large numbers of HGV’s.
The B1249 is accessed via a crossroads from the A165, the HGV traffic would travel through Beeford past Beeford C of E Primary School, the Sure Start Centre, our Community Centre, playground and numerous private properties built without true foundations whilst negotiating parked cars along the main street which Highways suggested was a good traffic calming and safety feature, particularly at the school.
There are serious concerns about the actual HGV numbers. The original application stated 6/7 in and out per day, this then went up to 34 two way per day in their Transport Statement. Reliable calculations of the amount of waste coming in and digestate going out show the figure is more likely to be a minimum of 60 trips per day, especially when spreading of digestate is in operation.
Many promises, suggestions and comments have been made by the applicant about avoiding traffic at school times and rush hour as well as villagers being able to choose the route for the HGV traffic and ‘timed’ deliveries but as stated in the Joint Waste Local Plan; ‘it is not within the power of the WPAs to impose route conditions on vehicles once they are on the public highway’.
Foston Lane is a narrow lane being 4.20m in part which will not accommodate 2 way HGV traffic as one HGV is 2.55m wide (excluding mirrors). Having said this, the Highways department have proposed putting passing places in but at this place it is not possible due to high banks and hedges and would contravene the East Riding criteria on hedgerows, i.e. 20m plus in length, 30 plus yrs old, bank acting as a support, less than 10% gaps and a parallel hedge within 15m.
Access via adjoining villages would also be unsuitable as they too have multiple blind bends, small bridges, schools and old buildings without footings.
Definition: “The quality of not being harmful to the environment or depleting natural resources, and thereby supporting long term ecological balance”
The Applicant has stated that waste will be sourced and transported from West Yorkshire, this would be a round trip of 150 miles. The costs involved in moving waste from source to Beeford shows the site is not environmentally friendly or economically sustainable.
No contracts or intentions for regular use of digestate have been secured locally neither are there any contracts or letters of intent for the supply of the food waste.
Requiring a fleet of heavy goods vehicle to facilitate this Waste Plant does not constitute green energy and this fleet of wagons would also cancel out the renewable energy purpose of the scheme.
12. Storage & Redistribution of waste
The applicant suggested that digested waste will be stored on site, plans provided do not show where extremely large volumes of liquid digestate will be stored safely, all tanks are named on the plans as ‘Main Tanks’ whilst in the text it is suggested that digestate is stored on site before being used on farmland.
A bund technically should contain 110% of the volume of the largest tank. If a slow leak at the bottom of a tank should occur the bund would retain the tanks volume.
The bund is only 1.2m high and the tanks are 13.5m in height. As has happened in the past elsewhere, if a sudden burst higher up in the tank or indeed a collapse of a tank occured, a low bund has no chance of containing the tanks content.
The Agent stated that 66,000 tonnes of digestate will be produced per annum, after approximately 25,000 tonnes of water is added, the figure for the digestate will be near 93,000 tonnes, the 33,000 tonnes that they stated could be spread on West Farm is impossible. In fact, in their Environmental Review & Supporting Statement 3.1.15 ‘around half of the digestate will be used on the adjacent farm with no larger scale movements on the wider road network’. DEFRA being the controlling body for digestate spreading/periods would be most interested in there figures. The landowner has approximately 600 acres which will not take this amount of digestate, it will probably only take around 10,200 tonnes, leaving 82,800 tonnes to be transported from site. It is also understood that some of the land is taken to growing peas which, as legumes, are not allowed to take digestate at all.
There are also restrictions on when the digestate can be spread. Again the agents have calculated wrongly stating 305 days. The proposed site is in the middle of a nitrate vulnerable zone and as such no spreading is allowed in October, November, December & January and there are limited periods during the remaining months due to the following conditions :
- When the ground is waterlogged, frozen or has a covering of snow.
- When the soil is cracked down to field drains or backfill, the field has been pipe or mole drained or sub soiled over the drains within the last 12 months.
- When heavy rain is forecast within the 48 hours.
Digestate cannot also be spread :
- On very steep slopes
Within 10 metres of a ditch, pond or other surface water.
- Within 50 metres of any spring, well, borehole or reservoir that supplies water for human consumption or for dairy farmers.
Disposing of the digestate will be a major problem as the Beeford area is prolific in pig farming hence they have there own slurry to spread.
13. Health & Wellbeing
Increased diesel emissions from the excessive number of HGV’s travelling through our villages. These emissions contain numerous hazardous pollutants including carbon monoxide (CO), nitrogen oxides (NOx) and particulate matter (PM). Particulate matter irritates the eyes, nose, throat and lungs contributing to respiratory and cardiovascular illnesses.
Hazardous substances are produced as part of the AD process. There will be a continuous flare burning.
Gas flares may emit methane and other volatile organic compounds as well as sulphur dioxide and other sulphur compounds which are known to exacerbate asthma and other respiratory problems. Other emissions may include aromatic hydrocarbons (benzene, toluene, xylenes) and benzapyrene, which are known to be carcinogenic.
Odour, Noise and Light pollution together with pollution to waterways and vermin are also of grave concern to health from residents.
‘There are no discernable benefits for our villages from this plant’
• It will affect our ‘sense of place’.
• Cause harm to visual amenity and landscape.
• Human Rights Act states that a person has the right to peaceful enjoyment of all their possessions which includes the home and other land.
• The character and distinctiveness of settlements and landscape should be protected.
• Good grade 2 agricultural land being sacrificed.
• Major concern for the future economy of our Rural Service Centre.
• Wrong place for an industrial waste plant of this size.
• Tourism and associated business in the area will be affected.
• Site Flooding issues / contamination to nearby watercourses.
• Pollution from noise, light and specifically odour.
• Safety concerns regarding the AD process and company having no track record.
• Road safety issues particularly near schools and down Foston Lane.
• No sustainable modes of transport maximised.
• No viable proof for disposal of digestate
• The East Riding has already contributed to renewable energy with numerous wind farms/turbines and three AD digesters in our area.
• Not ‘green’ energy with a fleet of wagons needed to supply feed stock increasing fossil fuel use.
• Not a viable renewable energy scheme.
• Not agricultural as majority of feed stock is brought in.
• Strength of feeling evidenced by over 700 objections.
• Waste plants should be as near as source as possible and in an industrial environment, not a blot on the rural landscape.