Design and Access/Planning Statement Proposed Anaerobic...

Design and Access/Planning Statement

Proposed Anaerobic Digestion Plant

Land East of A1, Gonerby Moor, Lincolnshire

On behalf of Moor Bio-Energy Ltd.

December 2015

Design & Access/Planning Statement: AD Plant, Gonerby Moor

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Design and Access Statement

Introduction

1.1 This Design and Access Statement has been prepared on behalf of Moor Bio-Energy Ltd.

in support of an application for planning permission for an anaerobic digestion plant,

landscaping, vehicular access and associated work, on land east of the A1 trunk road,

Gonerby Moor.

1.2 The Statement has been prepared in accordance with the Town and Country Planning

(Development Management Procedure) (England) (Amendment) Order 2013, and the

Council’s validation requirements.

2. Site and General Context

2.1 This report relates to proposed anaerobic digester plan to be located on an arable field

with a (save for the access part) rectangular application site. The site is bounded to the

north-west, north-east and south-west by hedgerows with scattered trees. The south-

eastern boundary is open, with Bees’ Gorse woodland located approximately 130 metres

further east. Access to the site will be via the B1174 and Gonerby Moor junction to the

A1 trunk road.

2.2 The application site comprises some 5.54 hectares, including access road.

Figure 1: Site Location (aerial)


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3. Proposed Development

3.1 The proposed development comprises the construction of a biomass fueled renewable

energy facility. The facility and process will convert locally sourced biomass

(approximately 60% farm waste and 40% maize and rye crops) into biogas and

biofertiliser. The biogas will be injected directly into the local National Grid gas network.

In addition, an organic biofertiliser will be produced from the anaerobic digestion

process.

3.2 The 4 MW biogas plant will generate clean, renewable energy from local biomass, which

would be brought to site via the B1174 and Gonerby Moor junction to the A1 trunk road.

The plant operates using an anaerobic digestion (AD) process, converting organic

material into biogas within a completely airtight, oxygen-free environment. The second

product of the process is a bio-fertiliser known as ‘digestate’. It is a naturally produced

fertiliser which is returned to the soil in both solid and liquid form. It is clean, safe

(approved for use on organic farms) and recognised as a valuable fertiliser for crops.

Digestate recycling reduces the amount of artificial chemical fertiliser required by local

farmers.

3.3 The waste element comprises only farm manures and slurries, from which the odours

are eliminated in the anaerobic digestion process (and contained within an air tight

storage/processing tank as gas). The other advantage is that this creates higher quality

fertilisers for local farms than would be the case by simply spreading unprocessed farm

waste on the land.

3.4 The proposed facility will consist primarily of three domed tanks (two digester tanks of

17.4m height x 30m diameter; one post-digester tank of 18.8m height x 34m diameter).

There would be three silage clamps measuring a total of 120m x 30m, together with

associated plant including holding pond, feed hoppers, CHP units, offices building and

weighbridge.

4. Assessment and Evaluation

Policy Context

4.1 For the purposes of this planning application, the Development Plan comprises the

Lincolnshire Minerals Local Plan (1991) and the Waste Local Plan (2006), together with

a number policies ‘saved’ under direction of the Secretary of State, in 2009. In addition

it comprises the South Kesteven Local Plan (Core Strategy – 2010 - and Site Allocations

and Policies Plan – 2014), together some saved policies of the 1995 Local Plan (but which

affect Grantham only).

4.2 The emerging Lincolnshire Minerals and Waste Local Plan, comprising the Core

Strategy and Development Management Policies Plans, are not yet part of the

Development Plan. They were submitted in June 2015, examined in October 2015 and

the Council is presently consulting upon Proposed Modifications to these Plans (to 08

January 2016). Full weight cannot be attributed to their policies to date but in

accordance with paragraph 216 of the NPPF, some weight can be applied to relevant

policies given their advanced stage in the examination process.


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4.3 The Planning and Compulsory Purchase Act 2004 requires that decisions on planning

applications must be made in accordance with adopted the Development Plan unless

material considerations indicate otherwise. This is reiterated in the National Planning

Policy Framework at paragraphs 11 and 12.

4.4 The accompanying Planning Statement includes a full assessment of the proposed

development in the context of current planning policy. Table 1 below sets out those

policies of the Development Plan that are considered relevant to the assessment and

evaluation of the site and its context, and in the formulation of development proposals.

National Planning Policy Framework (March 2012)

4.5 The National Planning Policy Framework was published on 27 March 2012. The

Framework now sets out the Government’s planning policies for England and how these

are expected to be applied, and is a significant material consideration in planning

decisions. In the context of this application, the following are considered to summarise

the relevant policies:

Implementation

For 12 months from publication of the NPPF, decision-takers may continue to

give full weight to relevant policies adopted since 2004, even if there is a limited

degree of conflict with this Framework. (paragraph 214)

In other cases and following the 12-month period, due weight should be given to

relevant policies in existing plans according to the degree of consistency with this

framework (the closer the policies in the plan to the policies in the Framework,

the greater the weight that may be given). (paragraph 215)

Sustainable Development

“There are three dimensions to sustainable development: economic, social and

environmental”. (paragraph 7)

“At the heart of the National Planning Policy Framework is a presumption in

favour of sustainable development, which should be seen as a golden thread

running through both plan-making and decision-taking. For decision-taking this

means [inter alia]:

o Approving development proposals that accord with the development plan

without delay (unless material considerations indicate otherwise).”

(paragraph 14)

Renewable Energy

One of the 12 core land-use planning principles of the NPPF is that “planning

should support the transition to a low carbon future in a changing climate...and

encourage the use of renewable resources (for example, by the development of

renewable energy)”. (paragraph 17)


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“Planning plays a key role in helping shape places to secure radical reductions

in greenhouse gas emissions, minimising vulnerability and providing resilience

to the impacts of climate change, and supporting the delivery of renewable and

low carbon and associated infrastructure. This is central to the economic, social

and environmental dimensions of sustainable development.” (paragraph 93)

“To help increase the use and supply of renewable and low carbon energy LPAs

should recognise the responsibility on all communities to contribute to energy

generation from renewable or low carbon sources. They should [inter alia]:

o Have a positive strategy to promote energy from renewable and low

carbon sources;

o Design their policies to maximise renewable and low carbon energy

development while ensuring that adverse impacts are addressed

satisfactorily, including cumulative landscape and visual impacts;”

o Consider identifying suitable areas for renewable and low carbon energy

sources, and support infrastructure, where this would help secure the

development of such sources.” (paragraph 97)

“When determining planning applications, LPAs should:

o Not require applicants for energy development to demonstrate the overall

need for renewable or low carbon energy and also recognise that even

small-scale projects provide a valuable contribution to cutting greenhouse

gas emissions;

o Approve the application if its impacts are (or can be made) acceptable.

(paragraph 98)

Design

• Good design is a key aspect of sustainable development, is indivisible from good

planning, and should contribute positively to making places better for people;

(paragraph 56)

• Design policies should avoid unnecessary prescription or detail and should

concentrate on guiding the overall scale, density, massing, height, landscape,

layout, materials and access; (paragraph 59)

• Permission should be refused for poor design that fails to take the opportunities

available for improving the character and quality of an area and the way it

functions. (paragraph 64)

Historic Environment

• In determining application, applicants should describe the significance of a

heritage asset and assess the impact of a proposal upon it. Where a site on which

development is proposed includes or has the potential to include heritage assets

with archaeological interest, developers should submit an appropriate desk-based

assessment and, when necessary, a field evaluation. (paragraph 128)


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Natural Environment

• The planning system should contribute to and enhance the natural and local

environment by [inter alia] protecting and enhancing valued landscapes, and

minimising the impacts on biodiversity and providing net gains in biodiversity

where possible; (paragraph 109)

Amenity

• Always seek to secure high quality design and good standards of amenity for all

existing and future occupants of land and buildings. (paragraph 17)

• The planning system should protect the local environment by [inter alia]

preventing development from contributing to or being put at unacceptable risk

from, or being adversely affected by noise pollution; (paragraph 109)

• Planning decisions should aim to avoid noise from giving rise to significant adverse

impacts on health and quality of life as a result of new development. (paragraph

103)

Transport

• Development should only be prevented or refused on transport grounds where the

residual/cumulative impacts of development are severe. (paragraph 32)

Rural Enterprise

• LPAs should support the sustainable growth and expansion of all types of business

and enterprise in rural areas, and promote the development and diversification of

agriculture and other land-based rural businesses. (paragraph 28)

Decision Taking

• LPAs should look for solutions rather than problems, and decision takers at every

level should seek to approve applications for sustainable development where

possible. (paragraph 187)

Local Development Framework

4.6 Table 1 sets out those policies of the Development Plan which are considered relevant to

the assessment and evaluation of the site and its context, and in the formulation of

development proposals.


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Table 1

Waste Local Plan 2006 (saved policies

- 2009)

Planning Policy Requirement

WLP11: Anaerobic Digestion and Mechanical Biological Treatment

Planning permission will be granted for anaerobic digestion and

mechanical biological treatment plants provided the following criteria

are met:

(i) any digestate produced as a residue of the process can be satisfactorily managed and disposed of; and (ii) that the site is located so as to minimise the traffic impact on the highway network. Favourable consideration will be given to those developments that propose multi-modal transportation, for example, waste movements by rail; and

(iii) such facilities will be permitted on land identified for general

industrial use (b2) or form an integral part of :

(a) sewage treatment plants; (b) intensive livestock units; (c) other waste management facilities; (d) associated with food processing facilities. and (iv) the proposal meets the criteria set out in policy wlp21; and (v) that the proposal is located at a distance from an occupied building (hotels, educational establishments, residential properties and institutions; other than properties in the same ownership as the proposed facility), that will allow any odour impacts upon the use of the occupied building(s) to be sufficiently mitigated against. The distance will be no less than 250 metres; and

(vi) self-sufficiency for operational energy and exportable energy

Recovery is maximised where appropriate; and

(vii) that with respect to anaerobic digestion plants, methane gas shall

be utilised in all but special circumstances; and (viii) the application is accompanied by a satisfactory odour impact assessment.

WLP21: Environmental Considerations

Planning permission will be granted for waste management facilities, having regard to (inter alia): agricultural land; airfield safeguarding; areas of landscape importance; woodland; drainage, flood protection and water resources; nature conservation; heritage; public rights of way, dust; odour; transport system; contamination.

South Kesteven Core Strategy – 2010

Planning Policy Requirement

EN1: Protection and Enhancement of the Character of the District

Development must be appropriate to the character and significant natural, historic and cultural attributes and features of the landscape within which it is situated, and contribute to its conservation, enhancement or restoration.

EN2: Reducing the Risk of Flooding

There is an initial presumption that preference should be given to locating new development in Flood Zone 1 areas. If there is no reasonably available site the flood vulnerability of the development can be taken into account in locating it within Flood Zone 2 and then Flood Zone 3.


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EN3: Renewable Energy Generation

The District Council will grant planning permission for proposals to generate energy from renewable sources, subject to the proposals according with the other Core Strategy policies, national guidance and complying with the following criteria: The proposal can be connected efficiently to existing national grid infrastructure, unless it can be demonstrated that energy generation would be used on-site to meet the needs of a specific end user. The proposal should make provision for: the mitigation of the real emissions/impacts arising from the

installation of the renewable energy generation;

the removal of the facilities and reinstatement of the site, should

the facilities cease to be operational.

EN4: Sustainable Construction and Design

Proposals for new development should consider and demonstrate how the design of buildings and site layouts use energy, water, minerals, materials and other natural resources appropriately, efficiently and with care and take account of the effects of climate change in accordance with other core strategy policies.

E1:Employment Development Outside Local Service Centres, rural diversification proposals will be supported where it can be demonstrated that it is necessary to meet the needs of farming, forestry, recreation, tourism or other enterprises and has an essential requirement for a rural location. Such proposals would need to demonstrate that they will help to support or regenerate a

sustainable rural economy.

4.7 Lincolnshire’s emerging Lincolnshire Minerals and Waste Local Plan, whilst not yet adopted, can be attributed some weight (see paragraph 4.2 above).

4.8 Relevant policies of the emerging Minerals and Waste Local Plan include:

Policy W3: Spatial Strategy for New Waste Facilities;

Policy W5: Biological Treatment of Waste Including Anaerobic Digestion and

Open-Air Composting;

Policy DM1: Presumption in Favour of Sustainable Development;

Policy DM2: Climate Change;

Policy DM3: Quality of Life and Amenity;

Policy DM4: Historic Environment;

Policy DM6: Impact on Landscape and Townscape;

Policy DM7: Internationally Designated Sites of Biodiversity Conservation

Value;

Policy DM8: Nationally Designated Sites of Biodiversity and Geological

Conservation Value;

Policy DM9: Local Sites of Biodiversity Conservation Value;


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Policy DM11: Soils;

Policy DM12: Best and Most Versatile Agricultural Land;

Policy DM13: Sustainable Transport Movements;

Policy DM14: Transport by Road;

Policy DM15: Flooding and Flood Risk;

Policy DM16: Water Resources;

Policy DM17: Cumulative Impacts.

Other Material Considerations

4.9 The principal material consideration is considered to be the National Planning Practice

Guidance, published in March 2014, insofar as it addresses matters concerning

renewable energy/climate change, noise, landscape, conserving and enhancing the

historic environment and the natural environment.

4.10 Other relevant Government planning and renewable energy policy to be considered in

the preparation and determination of the application include:

The UK Renewable Energy Strategy – 2009;

The UK Low Carbon Transition Plan – National Strategy for Climate and Energy

– 2009;

UK Biomass Strategy – 2007;

UK Bioenergy Strategy – April 2012 (DoT/DECC/DEFRA);

Anaerobic Digestion Strategy and Action Plan - June 2011 (DEFRA/DECC);

Climate Change Act – 2008;

Planning Act - 2008;

The Energy Act - 2008;

The EU Renewable Energy Directive (2009/28/EC).

4.11 A detailed assessment of the planning policy and related context – insofar as they relate

to these proposals - is set out in the Planning Statement section, below.

Physical/Landscape Context

4.12 The site comprises arable land just north of the A1 Trunk road; part of its access road is

the former A1 road. The site is located within the flat landscape on the eastern side of

the Vale of Belvoir. The site itself occupies part of a flat arable field with elevations of

approximately 35.5 metres AOD at the southern side and approximately 32 metres AOD

on the northern side, a change in 3.5 metres over a distance of 600 metres. The land

remains at approximately this level for several kilometres to the west. To the east and

south, the land rises dramatically at the Grantham Scarps, rising to an elevation of

around 110 metres AOD over a distance of 1200 metres from the Vale.


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4.13 The landscape around the application site is medium to large in scale, with relatively

simple regular arable fields, occasionally enclosed by hawthorn hedgerows, which are in

places fragmented. There are generally relatively few hedgerow trees and virtually no

woodlands within the character area, although the 4.6 hectare woodland of Bees’ Gorse,

to the west of the application site, is a notable landscape feature. It is particularly notable

in an otherwise relatively featureless landscape. A review of historical mapping shows

that this woodland was present with its current boundaries since at least 1890, and is

thus of historic interest. The mapping shows that several fields have been amalgamated

since the original mapping, although many original field boundaries remain.

4.14 The application site is bounded on its western and southern sides by established

(primarily Hawthorn) hedgerow, with four mature Oak trees within the hedgerow. The

Northern boundary marks the parish boundary between Marston Parish to the north,

and Great Gonerby to the south.

Economic Context

4.15 The proposed renewable energy facility has the ability to provide a range of economic

benefits locally and nationally. The facility will provide direct employment via:

Two on-site permanent employees to run and maintain the plant;

Employment of local contractors, haulage and plant hire for construction of the

facility;

Landscaping, fencing and security supplies;

Ongoing operational needs to employ local tradesmen for electrical, plumbing,

construction and general maintenance requirements.

4.16 Indirect employment/service requirements during construction and commissioning,

including:

Local hospitality/accommodation;

Catering and other facilities;

Purchase and maintenance of local workforce vehicles;

Taxi services.

4.17 The facility will also bring economic benefits by contributing to the Government’s

commitment to increase renewable energy in the UK by 15% by 2020, providing

increased security of energy supply over foreign fossil-fuel imports.

4.18 Local economic farming benefits will also accrue by offering farmers an opportunity to

grow financially viable break crops within existing rotations, delivering stable, long term

returns. UK farming has experienced a decline in Total Income from Farming (TIFF)

during recent years by over 6% and according to DEFRA these periods of volatility are

likely to occur over the foreseeable future. This type of diversification development will

assist in addressing that decline.


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Social Context and Community Involvement

4.19 In accordance with the provisions of the Localism Act 2011 and the Council’s Statement

of Community Involvement, prior to the submission of the application, consultation was

undertaken with Great Gonerby and Marston Parish Councils, and County and District

Council Ward councilors, via the provision of a preliminary plans and covering letter

seeking views. To date no response has been received. The objectives of community

engagement were to: raise awareness of the development and the importance of low-

carbon energy; provide an opportunity for interested parties to find out more; address

any concerns at an early stage in the preparation of the application. This reflects the

approach promoted by the NPPF (paragraph 66).

5. Design

Use

5.1 In light of the above assessment and evaluation, this application proposes the

construction of a locally sourced biomass fueled, renewable energy facility. The facility

and process will convert locally sourced biomass (approximately 60% farm waste and

40% maize and rye crops) into biogas and biofertiliser. The biogas will be injected

directly into the local National Grid gas network. In addition, an organic biofertiliser

will be produced from the anaerobic digestion process. The buildings and infrastructure

to be constructed will comprise plant and structures/tanks for the storage of feedstock

material and bio-fertiliser, the biogas digesters, holding pond, silage clamps, hoppers

and ancillary structures and buildings for the renewable energy process and site

management.

Amount of Development

5.2 The proposed application site is 5.54 hectares, including access road linked to the B1174

and Gonerby Moor junction to the A1 trunk road. The following principal structures are

proposed for the site:

Two x Digester Tanks: 17.4m high x 30m diameter;

Post Digester tank: 18.8m height x 34m diameter;

CHP unit: 15 m long x 4m wide;

Site Office building: 12m x 4m 3.2 high;

Three x Silage clamps: a total of 120m x 30m (three: 120m x 30m);

Feed hopper (28.6m long x 4.1m wide x 4.25m high);

Layout

5.3 The site has been selected as it is located close to a local biomass supply to reduce the

need for travel (the transportation of biomass to plant) and readily accessible to the

existing road network (the B1174 and Gonerby Moor junction to the A1 trunk road). The

site was also selected as it is has some natural vegetation screening and close to an

established cluster of large commercial and other buildings, around the Gonerby Moor

junction to the south and also to the north-west. There is also an established moto-cross

facility immediately to the south-east. The site is a good distance from houses,

minimising possible impacts from any noise and odours.


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5.4 The layout is shown on the accompanying plan (Ref. 20181 – 005 Rev. C). It represents

a standard layout for this type of development, largely dictated by operational

requirements. Nevertheless, it has been designed to take advantage of existing

structures/landscape features to aid integration into the wider landscape.

Scale

5.5 The scale of the component parts of the proposed development are explained in

paragraph 5.2, above, and are detailed in the accompanying drawings (20181 - 006, 007

and 010).

Appearance

5.6 The form and appearance of the structures and plant are largely influenced by function.

Nevertheless, attempts have been made to make the structures visually interesting

whilst acknowledging their utilitarianism. Consideration has been given to the advice

regarding development in the countryside contained within policies of the Development

Plan, in particular the siting and materials of such buildings. Design advice relating to

agricultural buildings is equally applicable to a renewable energy facility located in the

countryside.

5.7 The structures are to be constructed with a plain, grey, concrete finish and are intended

to be a recessive element of the landscape, with the general appearance of plain,

agricultural buildings. The matt finish to the buildings will avoid potential impacts due

to glare or reflections. The site’s development will benefit from extensive new tree

planting, and other landscaping.

6 Access

6.1 Relevant policies of the Development Plan seek to promote more sustainable transport

and to ensure that development proposals are capable of being served by safe access to

the highway network, without detriment to the amenity or character of the area.

6.2 Access to the site is available via an industrial estate road that connects with the B1174

Great North Road at a simple priority junction. The proposed development comprises

the construction of an Anaerobic Digestion facility – locally sourced crops and manure

will be converted into biogas and biofertiliser. The biogas will be injected into the local

National Grid gas network. The biofertiliser will be transported off-site and used by local

farmers on their fields. It is accepted that the location and nature of the proposed

development is such that the majority of trips associated with the site would be made by

vehicle.

6.3 No personal injury accidents have been recorded at the Great North Road junction with

the industrial estate access road which connects to the proposed development site. No

consistent factors are revealed by personal injury accident data recorded in the vicinity

of the site to suggest that the local highway network has any particular safety issues

which might be adversely affected by the proposed development.


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6.4 During the peak harvesting period the proposed development would generate around

60 vehicle movements per day, i.e. around 6 vehicle movements per hour – this is not a

material level of traffic generation. There is no reason to consider that the small

increases in traffic which would result from the proposed development would have a

detrimental impact on the operation of the local highway network, either in terms of

capacity or in terms of highway safety. The proposed AD facility will use material

produced by farms located relatively close to the site; these farms already grow crops,

and these crops are transported to factories or other locations for consumption which

requires use of the highway network. Similarly, the farms will already require the

delivery of fertilizer from an existing source. Consequently, although it is accepted that

there will be an increase in traffic movements on the local highway network in the near

vicinity of the site, there will be resultant reductions in traffic volumes elsewhere on the

wider highway network.

6.3 Further details are provided in the accompanying Transport Statement.

7. Conclusions

7.1 This Design and Access Statement demonstrates the process of appraisal, evaluation and

design for the proposed renewable energy (biogas) facility on land east of the A1 trunk

road at Gonerby Moor, Lincolnshire. From this process has emerged what the applicant

considers to be a contextually appropriate, sympathetic and sustainable development,

having regard to the constraints, characteristics and opportunities presented by this site

and its surroundings, together with relevant Development Plan (including those

emerging and well advanced) and national policies concerned with, access/highways,

amenity, design and the protection of the countryside/landscape.

------------------------------------


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Planning Statement

1. Background

1.1 The application site comprises arable land to the east of the A1 trunk road. The site is

bounded to the north-west, north-east and south-west by hedgerows with scattered

trees. The south-eastern boundary is open, with Bees’ Gorse woodland located

approximately 130 further east. Access to the site will be via the B1174 and Gonerby

Moor junction to the A1 trunk road. The application site comprises some 5.54 hectares,

including access road.

1.2 The proposed development comprises the construction of a biomass fueled renewable

energy facility. The facility and process will convert locally sourced biomass

(approximately 60% farm waste and 40% maize and rye crops) into biogas and

biofertiliser. The biogas will be injected directly into the local National Grid gas network.

In addition, an organic biofertiliser will be produced from the anaerobic digestion

process. The biogas plant will generate clean, renewable energy from local biomass,

which would be brought to site via the B1174 and Gonerby Moor junction to the A1 trunk

road. The plant operates using an anaerobic digestion (AD) process, converting organic

material into biogas within a completely airtight, oxygen-free environment. The second

product of the process is a bio-fertiliser known as ‘digestate’. It is a naturally produced

fertiliser which is returned to the soil in both solid and liquid form. It is clean, safe

(approved for use on organic farms) and recognised as a valuable fertiliser for crops.

Digestate recycling reduces the amount of artificial chemical fertiliser required by local

farmers.

1.3 The application has been prepared having regard to Development Plan and other

policies, together with the statutory and local validation requirements, and in particular

those policies and relevant issues and other material considerations set out in sections

3 and 4, below. To this end, prior to the preparation of the application, the applicants

have consulted with the Parish and County Councils, together with statutory and other

consultees.

1.4 The applicant and its consultants have established through consultation with officers of

the Council the requisite supporting information, assessment and reporting that should

accompany an application for the purpose of validation. An overview and evaluation of

this assessment work are set out below (section 4). Reports are included (in both digital

and paper form) with the application.

2. Proposed Development

2.1 The site, context and proposed development are described above in the Design and

Access Statement section of this document.

3. Planning Policy Context

Introduction

3.1 Section 38(6) of The Planning and Compulsory Purchase Act 2004 requires that

decisions on planning applications must be made in accordance with the adopted


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Development Plan unless material considerations indicate otherwise. This is reinforced

by the National Planning Policy Framework (NPPF) (paragraphs 11-12). Hierarchically,

the plan-led system can be viewed as follows:

• National Planning Policy (National Planning Policy Framework);

• Local Planning Policy (Local Development Frameworks/Local Plans and saved

policies of Local Plans).

3.2 The Design and Access section of this statement sets out the relevant policies of the

NPPF, in the context of these development proposals.

Development Plan

3.3 For the purposes of this planning application, the Development Plan comprises the

Lincolnshire Minerals Local Plan (1991) and the Waste Local Plan (2006), together with

a number policies ‘saved’ under direction of the Secretary of State, in 2009. In addition

it comprises the South Kesteven Local Plan (Core Strategy – 2010 - and Site Allocations

and Policies Plan – 2014), together some saved policies of the 1995 Local Plan (but which

affect Grantham only). The emerging Lincolnshire Minerals and Waste Local Plan,

comprising the Core Strategy and Development Management Policies Plans, are not yet

part of the Development Plan. They were submitted in June 2015, examined in October

2015 and the Council is presently consulting upon Proposed Modifications to these Plans

(to 08 January 2016). Full weight cannot be attributed to their policies to date but in

accordance with paragraph 216 of the NPPF, some weight can be applied to relevant

policies given their advanced stage in the examination process.

3.4 Table 1 of the accompanying Design and Access Statement summarises the relevant

Development Plan (Core Strategy) policies in the context of these proposals.

Other Material Considerations

3.5 Other material considerations relevant to the determination of this application include:

• The National Planning Policy Guidance (2014);

4. Evaluation and Assessment

4.1 The following sections provide an assessment of the planning policy context, and other

matters relevant to the determination of the application, including the assessments and

reports which accompany it, evaluating the proposed development against the

Development Plan and other relevant material considerations.

Sustainable Development

4.2 The NPPF introduces a clear and unequivocal presumption in favour of sustainable

development, requiring that development proposals be approved where they accord with

the Development Plan, unless material considerations indicate otherwise. Key

Development Plan policies include: saved Local Plan policies WLP11 (Anaerobic

Digestion and Mechanical Biological Treatment) and WLP21 (Environmental

Considerations), Core Strategy Policies EN1 (Protection and Enhancement of the

Character of the District), EN3 (Renewable Energy Generation) and EN4 (Sustainable


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Construction and Design). Emerging policies W5 (Biological Treatment of Waste), DM1

(Presumption in Favour of Sustainable Development), DM2 (Climate Change) and

DM13 (Sustainable Transport Movements), inter alia, are also material considerations

4.3 The application proposals are, in themselves, sustainable development in that they

propose the development of a renewable energy facility, the impacts of which would not

significantly or demonstrably outweigh its benefits. The application and its supporting

material, together with the remainder of this Planning Statement, demonstrate that

these development proposals accord with the NPPF and the policies of the Development

Plan.

Sustainable Energy and Climate Change

4.4 Key Development Plan policies include: saved Local Plan policy WLP11 (Anaerobic

Digestion and Mechanical Biological Treatment); Core Strategy Policies EN3

(Renewable Energy Generation) and EN4 (Sustainable Construction and Design). Also

material are, inter alia: emerging policies of the Minerals and Waste Local Plan, the

NPPF; the UK Renewable Energy Strategy (2009) and the UK Low Carbon Transition

Plan (2009).

4.5 The NPPF and other Government (energy) policy make it clear that planning has a key

role to play in combating climate change and creating an attractive environment for

innovation and for the private sector to bring forward investment in renewable and low-

carbon technologies, thereby helping the UK meet its international commitments and

targets for greenhouse gas emissions, including CO2. It makes a point of stating that:

“LPAs should recognise the responsibility of all communities to contribute to energy

generation from renewable or low carbon sources.”

4.6 Within this context, the application proposals are for a 4MWth biomass fueled

renewable energy facility. The plant will produce up to 35,000MWh of renewable

energy from local biomass, sufficient energy to serve around 2200 homes. Total CO2

emissions avoided (based upon a UK average of 0.36kg of CO2 per KWh of conventional

electricity) would be 12,000 tonnes/CO2 per annum.

4.7 It is apparent that the proposed development represents an innovative renewable energy

technology and is thereby consistent with the sustainable energy, climate change and

environmental objectives of Development Plan policy (and emerging policies), national

planning and renewable energy policy. Subject to it meeting the environmental and

amenity policy requirements of local and national policies (which the remainder of this

report demonstrates), then the development accords with relevant planning and related

policies. The development proposals also reflect and provide for the three dimensions

to sustainable development cited in the NPPF (paragraph 7).

Flood Risk, Surface and Ground Water

4.8 There are a range of policies concerned with the need to address the flood risk of new

development and the protection of surface and ground water. Namely: the NPPF and

its Technical Guidance, Core Strategy Policy EN2 (Reducing the Risk of Flooding),

together with emerging policy DM15 (Flooding and Flood Risk). These policies seek to

ensure that the sequential test set out in the NPPF Technical Guidance is applied and


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that most new development is located in Flood Zone 1. Additionally, they require that a

site-specific Flood Risk Assessment, which takes account of future climate change, is

undertaken for development proposals of 1 hectare or more in flood zone 1.

Furthermore, appropriate surface water drainage arrangements for dealing with surface

water run-off from new development should be provided including, if feasible, the use

of Sustainable Drainage Systems.

4.9 The Environment Agency’s Surface Water Flooding Maps indicates the site to be at very

low to high risk of surface water flooding. The southern half of the site is located in an

area of predominantly very low to low risk, with low to medium risk flooding to the

north. Limited areas of high risk flooding are identified in the north-western area of the

site. During the highest chance of occurrence surface water flood event (3.3% or greater

AEP), surface water flooding to a depth of over 900mm and velocity of greater than

0.25m/s is shown along the northern perimeter of the site at the location of a drainage

ditch. To a lesser extent surface water flooding is shown along the western boundary and

within the northern interior of the site to a depth of less than 300mm and velocity of less

than 0.25m/s. The remaining area of site is located in an area of very low flood risk.

Details of predicted amount of surface water run-off are set out in the accompanying

FRA.

4.10 A drainage ditch is located along the northern, southern and western perimeter of the

site boundary. A drainage ditch also follows the perimeter of the Bees’ Gorse mature

woodland to the east of the site.

4.11 The surface water from the hardstanding areas, clamp covers and bunded areas will

discharge into the attenuation pond via a surface water drainage system with an

interceptor and shut off valve. From the attenuation pond, surface water will discharge

to the ditch at a restricted rate through a flow control to ensure that the proposed site

does not increase the risk of surface water flooding off-site. The attenuation drainage

system will contain up to and including the 1 in 100 year storm event plus climate

change. The pond will be 2.0m deep which incorporates a 0.3m freeboard and will have

a storage volume of 1,920.9m3. The attenuation system will ensure that there is no above

ground surface water flooding during the 1 in 30 year rainfall event including climate

change. To prevent groundwater ingress the pond will be lined and weighted.

4.12 To reduce the risk and impact of flooding the following on-site mitigation methods are

recommended by the FRA:

The surface water runoff from the site will be contained in an attenuation system

designed to cope up to and including the 1 in 100 year storm event plus climate

change. The construction of the drainage features will result in the risk of flooding

from instantaneous runoff from the existing site onto the surrounding land being

reduced.

Access through less than 300mm of flood water at less than 0.50m/s is acceptable

for all, in accordance with R&D Technical Report FD2320/TR2 (13). However

where flood water exceeds this depth and velocity, site users should avoid walking

through the flood water, as it is considered to be dangerous for some/most.


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To prevent groundwater ingress the ponds will be lined and weighted.

4.13 The surface water runoff from the impermeable areas will discharge through the

following treatment stages, where the number of treatment stages are dependent on the

source of the runoff. The surface water runoff will be allowed to settle in the attenuation

lagoon to allow silt to fall out of suspension and aid in water quality. Silt traps will also

be used within the drainage system to improve water quality. To minimise the risk of

pollution to the aquifer, surface water from the bunded area will be inspected prior to

release into the attenuation pond. Should the inspection confirm the water is not clean

it will be released into the digestate storage lagoon for re-use in the process or tankered

off-site for appropriate disposal.

4.14 The surface water drainage system will drain surface water only; leachate collected

within the concrete silage clamps will discharge into a separate drainage system and be

contained within a leachate drainage system, prior to being fed into the digester tank to

be used within the process. In the event of a leachate spillage a shut off valve will divert

surface water to the leachate drainage system to prevent pollution to the attenuation

pond.

4.15 In summary, the FRA shows that with the mitigation measures put in place, the

proposed development will result in low risk to the site operators using the site. No

existing development adjacent or downstream of the site will be at an increased risk of

flooding due to the effects of the proposed development. Consequently, the proposals

accord with the relevant provisions of the NPPF and policies of the Development Plan

(including emerging policies) regarding flood risk, surface water drainage and

groundwater protection.

Landscape and Visual Impact

4.16 Relevant polices concerned with the protection of the landscape and visual impact

include: the NPPF; saved Local Plan policy WLP21 (Environmental Considerations) and

Core Strategy Policy EN1 (Protection and Enhancement of the Character of the District).

Emerging policy DM6 (Impact on Landscape and Townscape) is also a material

consideration.

4.17 The site is not located in any protected or designated landscape. A Landscape and Visual

Impact Assessment accompanies the application. The assessment addressed the

importance of any existing landscape features on the site, any historical features, and

neighbours affected, and the potential zone of visual influence of the proposals. The

assessment included both a desktop exercise and a thorough site assessment to

determine the potential viewpoints and extent of visibility. It concludes that:

The development will generally be less easily perceived within a flatter landscape,

where localised intervening obstruction such as woodland, hedgerows and subtle

changes in landform create effective screening. The application site itself is located

on flat ground interspersed with hedgerow, which indicates a low sensitivity.

However, the rising neighbouring land on Grantham Ridge allows some expansive

views over the Vale, indicating a higher sensitivity.


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New buildings in the rural landscape can create typically geometric form, and one

which is likely to contrast with more natural textures. The presence of a diversity

of land uses in the landscape will act to reduce sensitivity in this respect,

particularly if those uses include arable land, horticulture or brown-field sites,

whereas there is more likelihood that new development will stand out as a

significant change in a semi-natural landscape or one in which permanent pasture

features heavily. In this instance, the development is located close to existing

development and road and other infrastructure, but in a relatively simple open

landscape. The existing use and landform on the site here suggests a moderate

sensitivity.

New buildings in the rural landscape can create typically geometric form, and one

which is likely to contrast with more natural textures. The presence of a diversity

of land uses in the landscape will act to reduce sensitivity in this respect,

particularly if those uses include arable land, horticulture or brown-field sites,

whereas there is more likelihood that new development will stand out as a

significant change in a semi-natural landscape or one in which permanent pasture

features heavily. In this instance, the development is located close to existing

development and road and other infrastructure, but in a relatively simple open

landscape. The existing use and landform on the site here suggests a moderate

sensitivity.

The relative visibility of a landscape or distinctive elements within it, both from

within the character area and in relation to other character areas, will influence its

sensitivity. A landscape with a strong sense of enclosure is likely to be less sensitive

to development than a more open and exposed landscape in which the

development can be more readily perceived. In this instance, the site is within a

relatively open landscape with some expansive views. This suggests a higher

sensitivity.

Landscapes which show evidence of modern development, including settlement,

industrial and commercial development and infrastructure, tend to be less

sensitive to development. Landscapes which are relatively free from overt human

activity and disturbance, and which have a perceived naturalness, a strong feel of

traditional rurality or are dominated by historic rather than modern buildings, will

therefore be more sensitive. This is a pastoral landscape, but on the fringe of urban

development and with active road infrastructure. This suggests a lower sensitivity.

Overall, therefore, it is considered that the sensitivity of the landscape to this

particular type of development is judged to be moderate, in view of the

comparatively small distribution of significant landscape features and the

presence of urban development and road infrastructure. A landscape in

moderate/good condition whose characteristics or elements make some positive

contribution to wider landscape character. Containing landscape

characteristics/elements that are likely to be replaceable to some extent. In

considering any change, design and mitigation guidance should be followed.


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Whilst the domes cannot be ‘hidden’ using landscape mitigation, it is considered

that appropriate landscape measures will soften the appearance of the buildings

and screen the lower-level buildings and activity. This will enhance the minimalist

feel of the new buildings and reduce the overall visual perception of development.

It will help mitigate the higher sensitivity resulting from the overall levels of visual

exposure throughout the area, without being detrimental to the landscape

character. Planting should comprise reinforcement of the boundaries, using a mix

of native trees and shrubs compatible with locally-occurring types. There is an

opportunity to link the new planting with the existing Bees’ Gorse woodland to

provide ecological advantages, as well as aiding the new development to sit in the

landscape setting.

4.18 It is not therefore considered that the development will have such a significant, overall

impact upon the landscape character of the area so as to conflict with relevant national

or Development Plan policies (and emerging policies) concerning design, the protection

of the countryside and landscape impact.

Traffic and Transport

4.19 Relevant policy on traffic and transport is set out in: the NPPF; Core Strategy policies

DC15 (Renewable Energy) and CP14 (Sustainable Rural Communities). These policies’

primary objective is to promote more sustainable transport and to ensure that

development proposals are capable of being served by safe access to the highway

network, without detriment to the amenity or character of the area.

4.20 A Transport Summary accompanies the application. It advises/concludes the following:

Access to the site is available via an industrial estate road which connects with the

B1174 Great North Road at a simple priority junction.

The proposed development comprises the construction of an Anaerobic Digestion

facility – locally sourced crops and manure will be converted into biogas and

biofertiliser. The biogas will be injected into the local National Grid gas network.

The biofertiliser will be transported off-site and used by local farmers on their

fields. It is accepted that the location and nature of the proposed development is

such that the majority of trips associated with the site would be made by vehicle.

No personal injury accidents have been recorded at the Great North Road junction

with the industrial estate access road which connects to the proposed development

site. No consistent factors are revealed by personal injury accident data recorded

in the vicinity of the site to suggest that the local highway network has any

particular safety issues which might be adversely affected by the proposed

development.

During the peak harvesting period the proposed development would generate

around 60 vehicle movements per day, i.e. around 6 vehicle movements per hour

– this is not a material level of traffic generation. There is no reason to consider

that the small increases in traffic which would result from the proposed


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development would have a detrimental impact on the operation of the local

highway network, either in terms of capacity or in terms of highway safety.

The proposed AD facility will use material produced by farms located relatively

close to the site; these farms already grow crops, and these crops are transported

to factories or other locations for consumption which requires use of the highway

network. Similarly, the farms will already require the delivery of fertilizer from an

existing source. Consequently, although it is accepted that there will be an increase

in traffic movements on the local highway network in the near vicinity of the site,

there will be resultant reductions in traffic volumes elsewhere on the wider

highway network.

In relation to paragraph 32 of the NPPF, the report advises:

o Opportunities for sustainable transport – due to the nature of the proposed

development and its location there are limited opportunities for access by

pedestrians, cyclists and public transport users.

o Safe and suitable access – as demonstrated by the report, the site access

arrangements are satisfactory.

o Impact of development – the report demonstrates that traffic generated by

the proposed development would not have a severe impact on the operation

of the highway network.

4.21 The Transport Statement demonstrates that the overall vehicle movements to/from the

proposed facility would not be material in the context of existing vehicles on the local

highway network, especially when considering that these vehicles already operate on

that network through farming activity. Precise vehicle numbers are however difficult to

quantify and will vary depending upon the feedstock being used, load volume and

weather conditions (i.e. moisture content of crops); however, the estimates given are

based upon extensive experience gained by Northern Transport Planning Ltd. in relation

to numerous AD plants. Having regard to the above, it is considered that the proposed

development is satisfactory from a traffic and highway viewpoint. The proposed

development will have no material adverse impact upon the local highway system

(movement of feed stocks and biofertiliser) or any increased highway dangers to road

users or pedestrians. Consequently, the proposals accord with the relevant provisions

of the NPPF and policies of the Development Plan (including emerging policies)

regarding sustainable transport and highway safety.

Noise

4.22 The NPPF seeks to minimise noise impacts. Saved Waste Local Plan policy WLP21

(Environmental Considerations), Core Strategy policy EN3 (Renewable Energy

Generation), and emerging Minerals and Waste Local plan policies DM3 (Quality of Life

and Amenity) are concerned with the protection of amenity, which will include noise.

4.23 A Noise Impact Assessment accompanies the application, undertaken to identify key

noise sources associated with the AD Facility and to determine their potential impact


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upon the closest noise-sensitive residential receptors. A noise survey has been

completed in order to measure the background and ambient sound levels at a location

which was considered representative of the closest residential receptors to the Site.

4.24 The Noise Impact Assessment shows that the rating noise levels from the AD facility fall

below the adopted criteria. The calculated rating levels for both daytime and night-time

fall below the average measured background noise levels, which is classed as less than

‘low impact’. Given the favourable outcome of the assessment, noise should not be

considered a determining factor in the granting of planning approval for this AD Facility.

4.25 Consequently, the development proposals accord with the relevant provisions of the

NPPF and policies of the Development Plan (including relevant emerging policies).

Odour

4.26 The NPPF and Saved Waste Local Plan policy WLP21 (Environmental Considerations),

Core Strategy policy EN3 (Renewable Energy Generation), and emerging Minerals and

Waste Local plan policies DM3 (Quality of Life and Amenity) are concerned with the

protection of amenity, which will include odour.

4.27 An Odour Assessment report accompanies this application. Anaerobic digestion is a

sealed process and there will be no emissions to air during normal operational

conditions. The feedstock (biomass) will be stored as silage in sealed clamps (save for a

small area on the ‘active’ face of the clamps) to minimise dust and odour emissions

during storage.

4.28 Nevertheless, odours from a number of sources on site have the potential to cause

impacts at sensitive receptors. An Odour Assessment was therefore undertaken to

quantify impacts in the vicinity of the facility. Potential odour releases were defined

based on the size and nature of the proposed AD. These were represented within a

dispersion model produced using ADMS-5. Impacts at sensitive receptor locations in the

vicinity of the site were quantified, the results compared with the relevant odour

benchmark levels and the significance assessed in accordance with the IAQM guidance.

Predicted odour concentrations were below the relevant EA odour benchmark level at

all receptor locations for all modelling years. The significance of predicted impacts was

defined as negligible at all receptors. In accordance with the stated guidance, the overall

odour effects as a result of the proposed AD are considered to be not significant. As such,

potential odour emissions from the facility are not considered to represent a constraint

to the proposed development.


NPPF and policies of the Development Plan, including the emerging plan policies.

Archaeology and Cultural Heritage

4.30 Along with the NPPF, relevant policies concerned with the protection of the historic

environment include: Saved Waste Local Plan policy WLP21 (Environmental

Considerations), and Core Strategy Policy EN1 (Protection and Enhancement of the

Character of the District). Emerging Minerals and Waste Local plan policy DM4

(Historic Environment) is also a material consideration.


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4.31 An Archaeological Desk-Based Assessment was undertaken and accompanies the

application. The principal past impact on the site has been agricultural since at least the

post-medieval period. This is likely to have been pasture until relatively recently.

Ploughing may have impacted archaeological deposits if present. The proposed

development will entail the construction of ponds, silage clamps, feed digesters and

various ancillary structures. These will be concentrated in the north of the Site against

the western boundary. A proposed access road will traverse the southern part of the Site

to connect with the current access. These are all likely to entail excavation into below

ground deposits and could potentially impact archaeological deposits, if present.

4.32 Remains associated with later prehistoric and Romano-British settlement have been

identified in the vicinity, though none are recorded from the site itself. Despite this,

potential is considered to be low to moderate for remains of these periods being present.

There is a possibility of a Roman trackway, following the line of the parish boundary to

the north. If present, elements of the route (e.g. roadside ditches, borrow pits etc.) would

be affected by the construction of the northernmost lagoon. Medieval ridge and furrow

has been recorded in the vicinity of the site and there is some potential that furrows may

survive at depth and artefact spreads from manuring scatters may exist on the field

surface. A walkover survey identified no surface indications of archaeological interest

throughout the area of the site.

4.33 There are no Scheduled Monuments, and no listed buildings are present within the assessment area. There are also no conservation areas or registered parks and gardens.

4.34 Consequently, the proposed development accords with the relevant provisions of

national and Development Plan policy, including relevant emerging policies.

Ecology and Biodiversity

4.35 There are a range of policy documents that seek to ensure adequate protection of ecology

and biodiversity in considering development proposals. Relevant policies include the

NPPF, saved Waste Local Plan policy WLP21 (Environmental Considerations), and Core

Strategy Policy EN1 (Protection and Enhancement of the Character of the District).

Emerging Minerals and Waste Local plan policies DM7, DM8 and DM9 are also a

material consideration.

4.36 An Ecological appraisal accompanies the application. It concludes as follows:

The site of the proposed AD plant is an arable field of low ecological value, so the

development is not predicted to have significant negative ecological impacts.

Creation of the lagoons and green landscaping around the proposed buildings

would represent an ecological enhancement relative to the existing intensively

farmed arable field.

The potential for most protected species to occur on the proposal site itself is

judged to be low, with ground-nesting birds the only realistic exception. The

boundaries of the site, however, do provide habitats which are likely to be used by

nesting birds and may support roosting bats. These features should therefore be


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retained and protected using the avoidance and mitigation measures outlined in

the report. The primary aim of these measures will be to limit the disturbance

impacts of the AD plant on any animals which use the boundary habitats. Provided

these are adopted, no significant impacts to protected species are predicted, and

no further ecological surveys would be necessary.

There is also scope for ecological enhancement of the site once developed.

Recommendations regarding ecological enhancement are provided in the report,

and if these are adopted they would contribute to an overall long-term positive

ecological impact.


NPPF and policies of the Development Plan (including emerging policies) insofar as they

relate to ecological protection and biodiversity.

Employment and Agricultural Diversification

4.38 Key relevant policies on employment and agricultural diversification are set out in: the

NPPF, and Core Strategy policy E1 (Employment Development).

4.39 The NPPF states that LPAs should “promote the development and diversification of

agricultural and other land-based rural businesses.” (Paragraph 28). The application

proposes rural/agricultural diversification through the development of renewable

energy, enhancing the rural economy and agricultural viability. The proposed

development would create direct and indirect employment opportunities, short term

and long term, as well as providing for sustainable agricultural diversification.

5. Summary and Conclusions

5.1 The application is submitted on behalf of Moor Bio-Energy Ltd in support of a planning

application for the construction of an Anaerobic Digestion (renewable energy) facility,

on land to the east of the A1 trunk road at Gonerby Moor, Lincolnshire. The proposed

facility will convert locally sourced biomass (crops and farm waste) into biogas, which

will be injected directly into the local National Grid gas network. In addition, an

odourless organic biofertiliser and soil improver will be produced from the digestion

process, which will be returned to local farms as a replacement for artificial fertilisers

and to improve soil quality.

5.2 The development is proposed within the context of Government policy in respect of the

increasing need to address climate change and the promotion of renewable energy, and

the growth and diversification of the rural economy. The site location and development

proposals have been carefully considered, having regard to the constraints,

characteristics and opportunities presented by this site and its context, including those

issues addressed above.

5.3 The site location and development proposals have been carefully considered, having

regard to the various supporting assessments and findings which accompany the

application. The proposals would not give rise to any unacceptable environmental or


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other impacts and accord with the relevant Development Plan, emerging policies of the

Minerals and Waste Local Plan – which can be afforded some weight - and national

planning and renewable energy policies.

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