At a meeting on September 5th 2013 Oulton Parish Council voted to OBJECT to Planning Application No: 20130860: Erection of a Biomass Renewable Energy Facility on Land at Oulton Street, Norfolk, for Black Bridge Energy.
Oulton Parish Council’s reasons for this objection are set out below:
The Parish Council (PC) would like to state clearly at the outset that its members, both individually and collectively, understand the impact of global climate change, the urgent need for a global reduction in the emission of greenhouse gases and the contribution that renewable energy projects – amongst other responses - can make to this situation. This parish has already received and responded to, over the past 14 months, an application for a 48a solar farm and a separate application for a 77m wind turbine immediately adjoining the site of this Anaerobic Digester (AD) proposal.
The benefit of the AD proposal:
The PC makes no apology for initiating its response with a brief comment on the energy efficiency of this proposal and its carbon emissions, since central government policy weights the planning process heavily on the side of supporting renewable energy proposals, on these very grounds.
In terms of energy efficiency, the capacity factor (actual output, relative to theoretical potential, expressed as a percentage) of the above-mentioned solar and wind farms would have been - according to the developers - approximately 15% and 20% respectively. According to recent figures published on the Variable Pitch website, two other Anaerobic Digesters operated in this area by this applicant’s company report annual average capacity factors of 72.77% and 62.66%. Although these outputs are disappointing when compared to the company’s claim that anaerobic digestion “is reliably over 90% efficient”, the AD process is nonetheless a more substantial and less variable producer of electricity than solar or wind. The PC therefore acknowledges that this project is more useful to the National Grid than the other projects so far proposed.
In terms of carbon emissions, of course, anaerobic digestion of biomass (in this proposal, maize and grasses) is by no means neutral. The maize crop fixes carbon from the atmosphere as it grows, which is then released back into the atmosphere when the resulting methane gas is burned. This annual carbon cycle is neutral. 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. When government ministers make announcements supporting anaerobic digestion, they always refer in the first instance to on-farm digesters processing waste from the farm (e.g. pig or cattle slurry) and turning this into electricity for use on the same farm. Such a scenario is a perfect example of a continuously sustainable process. The proposal here is different: it is for a Centralised Anaerobic Digester (CAD) that is using a specially-grown crop as its feedstock, which is being transported in from a wide local area, and the resulting electricity is then sold to the National Grid at a subsidized rate. Nonetheless, the carbon emissions produced by the process are undeniably 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 new guidance on renewable energy will make clear to local planning authorities that the need for renewable energy “does not automatically override environmental protections and the planning concerns of local communities.” The new planning guidance also states that: “care should be taken to preserve heritage assets, including the impact of planning proposals on…their setting.” In a similar vein, the Communities Secretary, Eric Pickles, stated in June that: “Some localcommunities have genuine concerns that …insufficient weight is being given to environmental considerations like landscape, heritage and local amenity.”
The Energy Minister completed his announcement with the comment that renewable energy has “a big bright future in the UK, but not in any place, and not at any price.”
The Parish Council feels that this AD proposal may have some merit – but is it in the right place?
The costs of the AD proposal:
1)Industrialisation of the rural landscape.
1.1 This proposal is for a small, but nonetheless industrial-scale, gas-fired power station. Oulton is a quiet, rural parish, almost exclusively agricultural, devoted to the production of food. This statement applies also to the airfield: it is not a brownfield site. The AD will be fed by an agricultural product, but this will be used for an industrial purpose: the production of gas, to burn in an engine, to power a turbine, to generate electricity. In planning terms, this could be seen as a change of use of land in Oulton from agriculture to industry. As anaerobic digesters are still a relatively new technology, the planning process is currently struggling with this awkward interface between agriculture and industry – but the problems it generates for planning policy and local residents are very real.
1.2 Visually, the buildings are not attractive - however neatly maintained - and would present as an alien architectural feature in the landscape. In conjunction with the huge concrete apron necessary for the clamps, they would only contribute further to the degradation of the airfield as a rural landscape that was slowly returning to something more like its original character before it was cleared for the purposes of war. Over the past 70 years the airfield has been gradually re-populated with hedges and small copses of trees. It is this type of regeneration that should be encouraged - not the reverse. As the National Planning Policy Framework (NPPF) clearly states: “habitats that have been degraded can be restored” (Ministerial Foreword).
1.3 The effect of this AD proposal on the wider landscape also needs to be seriously considered. The applicant frequently mentions that maize is a highly desirable break crop: the implication is given that this will be an extra crop, somehow slotted in where there was an otherwise idle time on the land, restoring balance to the land after the ravages of commercial carrot-growing to supermarket standards. In fact, it has always been possible to grow maize in this area: it is neither a new idea nor a new part of the crop rotation. What is new is the enhanced price that the farmers will be given for their crop, as some of the government subsidy regime filters down through the renewable energy industry in the farmers’ direction. Up to now, maize has been grown in this area either as cover for pheasants, or as a fodder crop – thus supporting the production of milk and meat. The financial encouragement to grow an energy crop will in fact be an encouragement towards more monoculture, not less, in terms of the gradual disappearance of livestock farming in this part of Norfolk, hastening the time when only arable farming will be pursued here. The traditional mixed farming pattern in North Norfolk has shaped the particular, and much-loved, character of this landscape over centuries.
1.4 Tourists coming to this part of Norfolk do not come to stare at fields of maize. They come to visit the coast and the heritage assets, to see the cows grazing peacefully on the pastures of the Blickling Conservation Area (the whole eastern part of this parish) and the lambs gambolling at Easter around Mannington Hall. Oulton Parish Council urges the planning authority to think carefully before, by a series of planning permissions such as this, it gradually contributes towards killing the goose that lays the golden egg of income from tourism in this peaceful rural area of North Norfolk.
2)Creating a precedent.
In view of the above, the PC has significant concerns that, were this proposal to be approved, it would create a powerful and unwelcome precedent for the further industrial development of the airfield over time. The planning authority has already received a Request for a Screening Opinion for a solar farm on the airfield. The PC urges BDC to consider this situation very seriously.
3)Significant adverse impact on residential amenity.
3.1 HGV Traffic
This proposal has enormous traffic implications for the immediate and the surrounding area. Councillors and residents have put great time and effort into trying to ascertain some stable and credible figures on projected vehicle movements - but are not entirely convinced that they have yet discovered them. Set out below are summaries of some of the traffic scenarios that have been presented to us:
3.1.1The planning application Transport Assessment (TA) states:
30,000 tonnes will be moved by 15 tonne trailers and this will therefore generate 68 vehicle movements per day. This might be the case, if the average field weight per trailer-load were actually 15 tonnes, and if the harvest was spread over 60 days.
3.1.2 The Manager of Aylsham Growers(AG), the contracted suppliers of the feedstock, was recently able to explain to us that the average field-weight per trailer-load of his maize crop last year was 13.37 tonnes, which would generate, over 60 days, 76 movements per day. [See Appendix 1 for effects of variations in Dry Matter and Adjusted Weights on quoted figures.]
3.1.3 Some days earlier, the Manager of AG had indicated that the average trailer weight might be 10 – 12 tonnes. It emerged that this estimate was based on his (accurate) memory that the field weight trailer-loads of at least one of the cooperative’s growers (a very efficient farmer) had been exactly that. The factors affecting these variations in trailer-load weights are clearly very complex but, as they have an immediate and significant effect on the number of vehicle movements, it seems reasonable to work out also the resulting scenario:
30,000 tonnes / 11 (average of 10 – 12) = 2,727 loads delivered.
2,727 x 2 = 5,455 vehicle movements IN and OUT.
5455 / 60 days of harvest = 91 vehicle movements per day.
3.1.4 The Manager of AG also indicated that he was hoping to start harvesting this year on October 1st and that he would be expecting to have the whole maize crop delivered (to the AD at Scottow) within 3-4 weeks. Were this to happen at Oulton, this would more than HALVE the expected harvest period, but would therefore more than DOUBLE the number of vehicle movements per day. The scenario then could be:
5455 movements / 30 days = 182 vehicle movements per day.
3.1.5 To summarise: based only on information provided by the applicants at different times, we have been given 4 possible scenarios ranging from 68 vehicle movements per day at best, to 182 vehicle movements per day, at worst. In order to appreciate the impact on the narrow southern stretch of Oulton Street, it is important to visualize that the best-case scenario generates a vehicle movement every 7.5 minutes and that the worst-case scenario would generate one tractor and 15-tonne trailer unit passing up and down that single-track road every 3.3 minutes. This, of course, is not taking into account any of the already existing traffic on this, the only approach road to our village from the south.
3.1.6 A group of residents, formed expressly to look into the details of this application, produced another calculation of potential vehicle movements, based on a quoted figure for the density of forage maize of 80kg per cubic metre at a dry matter value of 35%. This calculation is appended here without further comment [See Appendix 2, Point 1.]
3.1.7 In view of all of the above, the PC has come to the conclusion that the goal of conclusive figures is unattainable. It will be up to BDC to decide whether it is wise or acceptable to give permission, on this scale and in this location, to such a very unpredictable and open-ended operation. This rural parish is accustomed, perforce, to absorbing the collateral damage of the current local food harvest. What is different about this situation is that it is proposed to create in Oulton Street a brand new hub - a collection point - for 30,000 EXTRA tonnes of harvest annually – the entire maize harvest of 18+ farms from a wide surrounding area. The only certainty is that the tractors and 15-tonne trailers carrying this crop will all be funnelled into this parish over a period of many weeks, every year for the next 25 years. The section of the C263 selected as the access road for this development contains one dwelling whose amenity would be grossly impaired, but it must also be stated that the village of Oulton Street is only 500m to the north and this is THE southern approach road to our quiet rural parish. Its character would be entirely transformed and degraded by the introduction of this type and volume of HGV traffic. It is Oulton Parish Council’s contention that this narrow, single-track rural lane –with or without passing places- is not capable of absorbing such a huge increase in HGV traffic and is therefore not a suitable access road for such an enterprise.
3.1.8 The Traffic Survey
The difficulty in receiving any stable or credible traffic movement figures related to the AD, as outlined above, is only one of the shortcomings of the TA:
The traffic data for the TA were collected by a survey during the last 2 weeks in August 2012. This period is atypical of the normal traffic flows along the C263 as it is during the school holidays, reflecting therefore nil traffic relating to school journeys and significant reductions in commuter traffic as so many people are away on holiday [See Appendix 2, Point 7]. The traffic survey, in order to provide credible base-line data for the TA, needs to be re-conducted during maize harvesting time (e.g. early October) in order to provide a truer picture of likely traffic pressures and conflicts. There is also no recognition at all in the TA of the fact that this section of the C263 is regularly used by cycling enthusiasts from the surrounding area and from Norwich who cycle down the full length of The Street on a weekly basis, both singly and in groups. The residents of Oulton Street themselves have an informal cycling group, involving families with children, whose itineraries annually include cycling down the C263 on their way to Cawston, Reepham and Heydon. The maize harvesting period, as indicated by this application, would represent a significant safety hazard to these other road users.
The accident risk is assessed only in respect of the junction of the B1149 and C263 and no data is provided, merely assertions about an ‘excellent accident record’. Even this assertion should be queried, as an accident is still vivid in the local memory of the time when an unwise ambulance driver, assuming the cars were pulling over, chose to drive at speed past a tailback of slow-moving traffic as he approached this very junction from the southeast. As he reached the C263, the tractor that had caused the tailback began to turn right into Oulton Street, the ambulance clipped the edge of it, was spun off the road and turned over. Fortunately, no-one was hurt, but it has given local residents pause for thought in the present discussion. Much more recently, only 6 weeks ago (9/8/13), a lorry and a van collided on the Blickling/Saxthorpe road, causing the road to be closed from the north end of Oulton Street up to the Saxthorpe roundabout for several hours. [See Appendix 3: Police accident data.]Note that this accident occurred between an HGV and a van, and that it took place on the very stretch of narrow road that would form the “northern distributor route” so to speak, for maize deliveries coming to Oulton from the north.
3.1.9 Passing Places
The application itself acknowledges that the southern section of the C263 is inadequate to the task of absorbing this scale and volume of traffic, and proposes to mitigate this problem by formalizing passing places. Concerned about the potential for loss of or damage to the mature trees along the roadside hedges of this section of the lane, the Parish Council has carried out its own survey, including photographs [See Appendix 4]. This survey was submitted to the Conservation Dept. at BDC. On the basis of a subsequent request from the Conservation Dept., the applicant has already re-submitted the plan, re-siting the passing places in sections of the roadway where they are less likely to damage trees. The PC appreciates this constructive response, although it had to point out to the Case Officer that the most northerly passing place is now proposed to be extremely close to the nearest dwelling to the site of the AD – The Old Railway Gatehouse – which would even further impact on the total loss of residential amenity for the inhabitants. A request has been made that this position should be re-considered. Although harder to predict, there is also very likely to be long-term damage, by compaction of the root systems, to the fine, established hedgerows. The PC has received a verbal offer from Mr. C. Harrold (the landowner at Docking Farm) to remove a section of the hedge on the Docking Farm bend, in order to improve visibility. As it would be a great shame to lose a hedge unnecessarily, the PC feels that it would be appropriate to wait at this point. However, it would like to register its appreciation of this offer, in the interests of safety.