Oulton Parish Council’s objection to Planning Application No: 20130860
Please note: all numbered points refer to the equivalent numbered points in the Full Response which is provided with these documents.
The Parish Council (PC) would like to state clearly that its members understand the impact of global climate change and the contribution that renewable energy projects – amongst other responses – can make to this situation.
The BENEFIT of the Anaerobic Digester (AD) proposal
Energy efficiency: unproven (difficult to achieve 90% as claimed) but better than wind or solar.
Carbon emissions: government ministers always refer positively to on-farm digesters processing waste from the farm (e.g. slurry) and turning this into electricity for use on the same farm. The proposal here is different however: it is for a Centralized Anaerobic Digester (CAD), using a specially-grown crop as its feedstock, contracted to be transported in from a wide area, the resulting electricity being sold to the National Grid at a premium (subsidized) rate. The annual carbon cycle of the maize is neutral; it fixes carbon as it grows, which is released back into the atmosphere when the methane gas is burned. However, quite apart from the carbon emissions involved in the materials used to build and equip the site operations, the emissions produced annually by the whole agricultural process needed to grow, harvest and transport the maize to the AD, tip the process back into being a net carbon dioxide producer. Nonetheless, the carbon emissions produced are less than those, say, of a coal-fired power station.
In planning terms, in relation to the central government directive to “presume to approve” renewable energy proposals, this is the benefit of the proposed anaerobic digester. What, however, are the costs?
The Energy Minister, Greg Barker, recently stated (July 2013) that the need for renewable energy “does not automatically override environmental protections and the planning concerns of local communities” and that renewable energy has “a big bright future in the UK, but not in any place, and not at any price.”
The PC feels that this CAD proposal may have some merit – but is it in the right place?
The COSTS of the CAD proposal
1) Industrialization of the rural landscape
1.1 This facility is a gas-fired power station, yet this is neither an industrial nor a brownfield site. Change of use from agriculture to industry has not been acknowledged.
1.2 These industrial buildings would be an alien architectural feature in the rural landscape. 1.3 Energy maize will divert productive arable land from food to fuel.
1.4 Increasing industrialization of the rural landscape of N. Norfolk risks loss of income from tourism in this area.
2) Creating a precedent: Approving this proposal would create a dangerous precedent for the further industrial development of this piece of land. A wind turbine next to this site hasalready been proposed and possibly also a solar farm.
3) Significant adverse impact on residential amenity
3.1 HGV Traffic: this proposal has enormous traffic implications for the immediate and surrounding area. The PC believes the application data is misleading – from information provided by the applicant at different times, we have 4 possible scenarios ranging from 68 vehicle movements per day at best (8 passes per hour), to 182 vehicle movements per day – worst-case scenario generates one HGV passing every 3.3 minutes in both directions on a single-track rural lane. During many daylight hours there are currently NO Heavy Goods Vehicles using this lane, so this represents, at least, an 800% increase in HGV traffic.
3.1.8 The Traffic Assessment has serious deficiencies: traffic flow data was collected in AUGUST – an atypical time – no school journeys, reduced holiday-time commuter traffic.Accident data is too vague and optimistic. Only at a very late stage has the applicant sought to address some of these issues after discussions with the Case Officer.
3.1.9 Passing Places: The application acknowledges that the southern section of the single-track C263 – one whole kilometre in length – is inadequate to the task of absorbing this type and volume of traffic, and proposes to mitigate by formalizing passing places. The use of passing places as a solution to the patent inadequacies of the C263 as a two-way HGV access road is at best clumsy and at worst unsafe. Passing places must only be a solution of last resort – they should never be relied upon, from the outset, as an integral part of a traffic management scheme for a project as large as this.
3.1.10 Total loss of residential amenity to the Old Railway Gatehouse: the increase in HGV traffic generated by this proposal would impact severely on the dwelling directly alongside this section of narrow lane – The Old Railway Gatehouse – which is situated only 170m from the AD site. Every single vehicle movement passing into and out of this AD site, at any time of year, would pass directly alongside this house, whose mature garden, established over 20 years, also abuts the road. The noise, vibration and visual intrusion of this continual HGV traffic would render life in the Gatehouse extremely unpleasant and life in the garden intolerable. It is certainly difficult to envisage how the applicant could mitigate in any significant way for the total loss of residential amenity for this dwelling.
3.1.11 Alternative Access: The PC arranged an informal meeting with the landowner, suggesting that a dedicated access route to the proposed AD could be created directly off the Holt Road, thus avoiding use of the C263 altogether. Unfortunately, the landowner felt unable to pursue further any of the ideas proposed by the parish council.
3.1.12 The Section 106 Unilateral Undertaking: an increase in HGV traffic would be unacceptable through the village of Oulton Street. The proposal is to control this by a Unilateral Undertaking. The PC has serious reservations about the wording – the definition of Exempted Vehicles and complete lack of clarity about meaningful signage would render the document unenforceable. The applicant’s response to the PC has been limited and too late to be useful. The PC remains concerned that the Committee is being expected to determine this application with the Undertaking in such an unsatisfactory state, especially as this echoes post-permission difficulties with planning conditions that remain outstanding at Taverham three years later. The residents should not become perpetual policemen in the monitoring of breaches.
3.1.13 The PC has concerns about the use of the joint access being shared between the proposed AD and Saltcarr Farms, complicating the issue of any effective monitoring of vehicle movements into and out of the site. The use of adjoining access to the landowner’s farm at one of the ADs in Taverham has severely hampered monitoring of the site operations there.
3.1.14 Conclusion of Section 3.1 – Traffic Implications: Oulton Parish Council is forced to conclude that, under the terms of Policy GS3(d) of the BDC Local Plan, the proposed means of access to this development, and the surrounding highway network, do NOT have “the ability to accommodate the traffic likely to be generated, without significant detriment to the character of the area, the amenity of nearby occupiers, or highway safety.”
3.2 Potential for Noise Disturbance: 3.2.1 No account is taken of:
- the prevailing wind comes from the southwest – 24 dwellings exist only 500m downwind.
- no mention of cumulative impact from E.F.Harrold and poultry farm immediately adjacent.
- no mention of effect of a continuously running engine on Oulton Street village which, at night, is an entirely silent place. Noise effects are only assessed to South and West of site.
3.2.2 and 3.2.3 Oulton PC has concerns about other potential noise sources, including the use of reversing alarms, the feed hopper, clamp rolling and filling and the use of the flare.
3.3 Potential for Odour Nuisance:
- the odour is classified as “moderately offensive”(e.g.’intensive livestock’)
- no mention made of malodorous intensive poultry rearing immediately adjacent to site
- any increase in “moderately offensive” odour would be completely unacceptable in terms of the cumulative impact on loss of residential amenity, in contravention of Policy GS3(e).
3.4 Emissions: Deficiencies of Emissions Assessment:
3.4.1 meteorological data derived from Marham – 44 km from this site. How useful is this?
3.4.2 No mention of the adjacent turkey farm – already emitting significant particulates. Cumulative impact of emissions would therefore have to be taken into account.
-Section 4.3 of the Assessment uses some data that is spectacularly out of date.
3.4.3 Cumulative effect of emissions from massive increase in HGV traffic is ignored.
4) Adverse impact on the natural environment.
4.1 Both the planting scheme and the management plan are unrealistic and therefore unlikely to be carried out effectively. 4.2 At Taverham the planting in the landscaping scheme did not take place and became the subject of an Enforcement Notice.
4.3 No mention at all of the long-term maintenance of the planting scheme.
4.4 4.07 ha (10.05 acres) of productive agricultural land will have been lost from food production. This is not a brownfield site. Flocks of lapwings – barn owls nesting – buzzards soaring – 5 species of bat identified. This development would impact adversely on the natural environment, in contravention of Policy GS3 (g) and (h) of the Local Plan.
5) Significant adverse impact on the historic environment.
There is no assessment at all of this issue in the application.
5.1 There are 17 Listed Buildings and 3 Conservation Areas (CAs) within 5 km of the proposed CAD site: Heydon CA is 750m to the south and Blickling CA only 550m to the north. The site of this gas-fired power station is slotted into a tiny parcel of land between 2 major Conservation Areas, created precisely to protect these national heritage assets and their settings from inappropriate development. The presence of these heritage assets attracts thousands of visitors to this part of North Norfolk every year. The risk of compromising this economic benefit to the area will have to be carefully considered by BDC when they weigh up the possible economic benefits of the CAD. See also The National Trust’s Response.
5.2 Significant adverse impact on an undesignated heritage asset.
- large sections of the 2 main runways, service tracks and buildings of RAF Oulton remain.
- Blickling Hall has recently enlarged the RAF Oulton Museum permanent exhibition, because of the inextricable connection between Blickling Hall and Oulton airfield during WWII.
- the airfield, and the whole of Oulton Street, is a site of annual pilgrimage for the RAF 100 Group veterans and their burgeoning families.
- This place matters to people, both past and present.
5.3 The southwestern boundary of the Blickling CA was re-drawn several years ago, specifically to include and protect the vernacular architecture of the cottages all along Oulton Street and the ancient pattern of tiny fields and hedgerows behind them. Some of these fields, being freehold, were judged to be at potential risk of inappropriate development. This industrial facility, in itself and with its traffic implications, is inappropriate and unacceptable, so close to so many Conservation Areas, contravening Policy GS3 (i).
This proposal, in terms both of its installation and its operations, would significantly adversely impact on the residential amenity of all the inhabitants of Oulton Street, utterly destroy the amenity of the Railway Gatehouse and degrade the special qualities of this rural locality.
This industrial facility would be better sited on or adjacent to an industrial estate, with the benefit of appropriate access roads designed to handle continuous two-way movements of HGV traffic.
Oulton Parish Council, for all the reasons set out above, urges Broadland District Council to REFUSE this application.