Enviroguide Consulting Environmental Impact Assessment …Biodiesel produces fewer emissions than...

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Enviroguide Consulting Environmental Impact Assessment Report College Proteins EIAR Volume 2: Section 1 i Contents LIST OF FIGURES ________________________________________________________ ii LIST OF TABLES _________________________________________________________ ii 1.1 Introduction ________________________________________________________ 1 1.2 Overview of the Proposed Development ________________________________ 1 1.2.1 Need for the Proposed Development ________________________________ 2 1.2.2 Alternatives Considered __________________________________________ 4 1.3 Site Description _____________________________________________________ 5 1.4 Planning and Policy Context __________________________________________ 8 1.4.1 National Framework Plan _________________________________________ 8 1.4.2 Regional Planning Guidelines _____________________________________ 9 1.4.3 Meath County Development Plan 2013-2019 __________________________ 9 1.5 Environmental, Energy and Transport Policy ____________________________ 9 1.5.1 EU Policy ________________________________________________________ 9 1.5.1.1 Introduction _____________________________________________________ 9 1.5.1.2 The EIA Directive ________________________________________________ 9 1.5.1.3 Kyoto Protocol to the Convention on Climate Change ___________________ 11 1.5.1.4 Animal By-Products Regulation 2002 ________________________________ 11 1.5.1.5 The EU Emission Trading Scheme (ETS) ____________________________ 12 1.5.1.6 The Renewable Energy Directive 2009 ______________________________ 13 1.5.1.7 The Fuel Quality Directive 2009 ____________________________________ 14 1.5.1.8 The Seventh Environment Action Programme (2012-2020) (EAP) _________ 15 1.5.1.9 The Paris Agreement 2015 ________________________________________ 15 1.5.1.10 The Resource Efficiency Roadmap ________________________________ 16 1.5.1.11 EU Waste Framework Directive and European Community (Waste Directive) Regulations 2011 _____________________________________________________ 16 1.5.2 National Policies _______________________________________________ 17 1.5.2.1 National Strategy on Biodegradable Waste ___________________________ 17 1.5.2.2 2006 Green Paper Towards a Sustainable Energy Future for Ireland ______ 18 1.5.2.3 2007 White Paper- Delivering a Sustainable Energy Future for Ireland ______ 18 1.5.2.4 Waste Management (Food Waste) Regulations 2009, S.I. 508 of 2009______ 18 1.5.2.5 Energy (Biofuel Obligation and Miscellaneous Provisions) Act 2010 ________ 18 1.5.2.6 A Resource Opportunity-Waste Management Policy in Ireland 2012 ________ 19 1.5.2.7 Strategy for Renewable Energy 2012 -2020___________________________ 19 1.5.2.8 Draft Bioenergy Plan 2014 ________________________________________ 20 1.5.2.9 2014 Green Paper- Energy Policy in Ireland __________________________ 21 1.5.2.10 2015 White Paper -Ireland’s Transition to a Low Carbon Energy Future 2015- 2030 _______________________________________________________________ 21 1.5.2.11 AgriVision 2015 Action Plan _____________________________________ 21 1.5.2.12 The National Waste Prevention Programme (NWPP) Annual Report 2014 __ 22 1.5.3 Local Policy ___________________________________________________ 22 For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 18-09-2018:03:33:35

Transcript of Enviroguide Consulting Environmental Impact Assessment …Biodiesel produces fewer emissions than...

Page 1: Enviroguide Consulting Environmental Impact Assessment …Biodiesel produces fewer emissions than the conventional fossil fuels. In this process, used cooking oil (UCO) and animal

Enviroguide Consulting Environmental Impact Assessment Report

College Proteins EIAR Volume 2: Section 1 i

Contents

LIST OF FIGURES ________________________________________________________ ii

LIST OF TABLES _________________________________________________________ ii

1.1 Introduction ________________________________________________________ 1

1.2 Overview of the Proposed Development ________________________________ 1

1.2.1 Need for the Proposed Development ________________________________ 2

1.2.2 Alternatives Considered __________________________________________ 4

1.3 Site Description _____________________________________________________ 5

1.4 Planning and Policy Context __________________________________________ 8

1.4.1 National Framework Plan _________________________________________ 8

1.4.2 Regional Planning Guidelines _____________________________________ 9

1.4.3 Meath County Development Plan 2013-2019 __________________________ 9

1.5 Environmental, Energy and Transport Policy ____________________________ 9

1.5.1 EU Policy ________________________________________________________ 9

1.5.1.1 Introduction _____________________________________________________ 9

1.5.1.2 The EIA Directive ________________________________________________ 9

1.5.1.3 Kyoto Protocol to the Convention on Climate Change ___________________ 11

1.5.1.4 Animal By-Products Regulation 2002 ________________________________ 11

1.5.1.5 The EU Emission Trading Scheme (ETS) ____________________________ 12

1.5.1.6 The Renewable Energy Directive 2009 ______________________________ 13

1.5.1.7 The Fuel Quality Directive 2009 ____________________________________ 14

1.5.1.8 The Seventh Environment Action Programme (2012-2020) (EAP) _________ 15

1.5.1.9 The Paris Agreement 2015 ________________________________________ 15

1.5.1.10 The Resource Efficiency Roadmap ________________________________ 16

1.5.1.11 EU Waste Framework Directive and European Community (Waste Directive)

Regulations 2011 _____________________________________________________ 16

1.5.2 National Policies _______________________________________________ 17

1.5.2.1 National Strategy on Biodegradable Waste ___________________________ 17

1.5.2.2 2006 Green Paper – Towards a Sustainable Energy Future for Ireland ______ 18

1.5.2.3 2007 White Paper- Delivering a Sustainable Energy Future for Ireland ______ 18

1.5.2.4 Waste Management (Food Waste) Regulations 2009, S.I. 508 of 2009______ 18

1.5.2.5 Energy (Biofuel Obligation and Miscellaneous Provisions) Act 2010 ________ 18

1.5.2.6 A Resource Opportunity-Waste Management Policy in Ireland 2012 ________ 19

1.5.2.7 Strategy for Renewable Energy 2012 -2020 ___________________________ 19

1.5.2.8 Draft Bioenergy Plan 2014 ________________________________________ 20

1.5.2.9 2014 Green Paper- Energy Policy in Ireland __________________________ 21

1.5.2.10 2015 White Paper -Ireland’s Transition to a Low Carbon Energy Future 2015-

2030 _______________________________________________________________ 21

1.5.2.11 Agri‐Vision 2015 Action Plan _____________________________________ 21

1.5.2.12 The National Waste Prevention Programme (NWPP) Annual Report 2014 __ 22

1.5.3 Local Policy ___________________________________________________ 22

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College Proteins EIAR Volume 2: Section 1 ii

1.5.3.1 The Waste Management Plan for the Eastern-Midlands Region 2015-2021 __ 22

1.6 Structure of the Environmental Impact Assessment Report. _______________ 23

1.7 Consultation and Scoping ___________________________________________ 25

1.7.1 Scoping Request _______________________________________________ 25

1.7.2 Scoping Responses _____________________________________________ 28

1.7.3 Public Consultation _____________________________________________ 29

List of Figures

Figure 1:................................................................................................................................ 1

Figure 2:................................................................................................................................ 5

Figure 3:................................................................................................................................ 6

Figure 4:................................................................................................................................ 7

Figure 5:.............................................................................................................................. 15

Figure 6:.............................................................................................................................. 19

Figure 7:.............................................................................................................................. 26

List of Tables

Table 1: ............................................................................................................................... 12

Table 2: ............................................................................................................................... 18

Table 3: ............................................................................................................................... 22

Table 4: ............................................................................................................................... 24

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College Proteins EIAR Volume 2: Section 1 Page 1 of 27

1.1 Introduction

College Proteins of College Road, Nobber Co. Meath has been operating at this site since

1989 and is now Ireland’s leading processor of animal by-products. College Proteins collects

and processes animal by-products from abattoirs, meat plants, butchers and poultry plants.

The main raw materials are inputted into the existing plant and cooked and separated to

produce tallow and meat and bone meal (MBM). These two products are renewable

indigenous, carbon neutral fuel. The activities of College Proteins are oriented towards

servicing the local, regional and national markets.

The facility at College Road currently operates under an Industrial Emissions Licence from the

Environmental Protection Agency register number P0037-03.

1.2 Overview of the Proposed Development

Figure 1 Location of site

The proposed development consists of the construction of a Biodiesel manufacturing facility

adjacent to the existing meat rendering plant on the College Proteins site at College Road,

Nobber, Co. Meath. Planning permission was sought from and granted by Meath County

Council for this project in 2016 (KA 160786). However a refinement to this process is now

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College Proteins EIAR Volume 2: Section 1 Page 2 of 27

possible which produces two biodiesel type, namely a standard C16 product and a low

freezing point C18 biodiesel which can be used in cold temperate countries. This process

adjustment also improves efficiencies and reduces the amount of waste generated. As a result

some changes to the proposed infrastructure are required which in turn require planning

permission. This revised Environmental Impact Assessment Report (EIAR) is submitted in

support of this planning application.

When operational, the Biodiesel plant will convert tallow (a by-product from the Company’s

existing process) into a high quality bio-degradable fuel known as Biodiesel. Biodiesel can be

used as a clean, environmentally friendly alternative to conventional carboniferous fuels, thus

reducing greenhouse gas emissions. Some of the benefits of Biodiesel are:

Biodiesel is a renewable fuel produced from animal fats or vegetable oils.

In the transport sector, it may be effectively used both when blended with fossil diesel fuel and in pure form.

Biodiesel produces fewer emissions than the conventional fossil fuels.

In this process, used cooking oil (UCO) and animal fat (AF) represent a very high-grade source

of energy (fuel for diesel engines) when they are chemically changed (transesterified). In

chemical respect, fats and oils consist mainly of free fatty acids and triglycerides (i.e. three

long-chain fatty acids are attached to a trihydric alcohol, the glycerine). These components

can be transformed into Fatty Acid Methylester (FME) also called Biodiesel, a fuel directly

useable in diesel engines, fulfilling the worldwide strictest quality standard (EN14214).

The process can be divided in two main parts:

1. Esterification and transesterification of the raw material to Biodiesel 2. By-product treatment (glycerine processing)

The process technology for the production of Biodiesel has been developed thoroughly and is

focused on the environmental compatibility, i.e. by-products represent valuable products,

which increase the economic output.

1.2.1 Need for the Proposed Development

The Applicant is committed to providing practical sustainable solutions both at a local and

national level. The need for this development can be presented at both of these levels. The

raw material for the Biodiesel plant, tallow, is produced on site as a by-product of the existing

process. Currently it is transported offsite for conversion into Biodiesel, both in Ireland and

abroad. The proposed development will eliminate the requirement for this and provide the

capacity for additional processing which will aid national self-sufficiency in this regard. Thus

the project will aid the conversion of tallow into a high value product.

On a national level the use of biofuels is considered to be carbon neutral under the Kyoto

Protocol. The quantity of carbon dioxide released by the combustion of plant derived fuel is

considered to be equal to the carbon dioxide absorbed during its growth cycle. The substitution

of fossil fuels with Biodiesel is consistent with this approach and will contribute to Ireland

meeting its Kyoto obligations.

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It has been determined that the Biodiesel made from animal fat reduces greenhouse gas

emissions by 85% compared to fossil fuels. This has been confirmed by the findings of The

Institute for Energy and Environmental Research (IFEU) in Heidelberg.

Directive No. 2009/28/EC known as the Renewable Energy Directive obliges each Member

State to ensure that the share of energy from renewable sources in all forms of transport in

2020 is at least 10% of the final consumption of energy in that Member State. The blending of

biofuels is one of the methods available for Member States to meet this target, and is expected

to be the main contributor.

The weighted share of biofuels in Ireland as a percentage of petrol and diesel energy use was

4.8% in 2013, up from 3.9% in 2012 and 0.5% in 2007. As stated above the target for 2020 is

10% (Source SEAI).

Directive 2009/28/EC also stresses the need for energy efficiency in the transport sector which

is imperative because a mandatory percentage target for energy from renewable sources is

likely to become increasingly difficult to achieve sustainably if overall demand for energy

continues to rise.

Therefore, and due to the importance of energy efficiency also for greenhouse gas emission

reduction, Member States and the Commission are encouraged to include more detailed

information in the transport sector in their reports to be submitted in accordance with Annex

IV to Directive 2012/27/EU.

This proposed development will assist Ireland achieving these mandatory targets by

increasing the tonnage of Biodiesel available for use in this country.

Currently Ireland produces approximately 80,000 tonnes of tallow per annum (source Dept. of

Agriculture) for which there is currently 30,000 tonnes of indigenous processing capacity for

its use in Biodiesel. If permitted the proposed development will provide a significant

contribution to Ireland’s efforts to become self- sufficient in this regard.

Ireland imported 126 million liters of biofuel in 2013 – some 84% of the total 150m liters

used. Taking the sector as a whole, around half of all the biofuel used in Ireland is derived

from used cooking oil (49%), one quarter comes from corn (24%), while tallow from meat

rendering plants makes up one in every eight liters (12.5%). The other feedstocks that go to

make biofuel used in Ireland are wheat, sugar beet, sugar cane, palm oil mill effluent and

rape seed.

Policy documents from the EU such as ‘The Resource Efficiency Roadmap’ and the

Governments document ‘A Resource Opportunity-Waste Management Policy in Ireland’

highlight a sea change in opinion which now material such as tallow as a valuable resource

with a huge economical potential. Through the recycling of this material at the subject

development a far more sustainable product namely Biodiesel is created then would be the

case if the facility did not exist and the material was simply used as boiler fuel.

There is clearly a need to address this situation, not just to meet the EU’s targets, but to ensure

that this material is used for more sustainable job creating purposes. The need for much more

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rapid progress in the provision of sustainable alternatives was highlighted in the EPA’s

National Waste Report for 2013.

The tonnages proposed by the subject development are 25,000 tonnes and the development

will require an Environmental Impact Assessment Report. It is also proposed to apply to the

Environmental Protection Agency to review Industrial Emissions Licence number to include

this proposed facility.

1.2.2 Alternatives Considered

Schedule 6 of the Planning and Development Regulations, 2001, sets out the mandatory

information that must be contained in an Environmental Impact Statement. Section 1(d) of this

Schedule states that; ‘an outline of the main alternatives studied by the developer and an

indication of the main reasons for his or her choice, taking into account the effects on the

environment’. These main alternatives are not confined to alternative locations and for the

purposes of the Regulations alternatives may be described as;

Alternative Locations

Alternative Designs

Alternative Processes

Once the need for a 25,000 tonne facility was identified The Applicant examined the

alternatives. There were three main alternatives considered in terms of the proposed

development. These options were as follows:

1) Open a new 25,000 tonne facility on a Greenfield site.

2) Open a new 25,000 tonne facility on another site owned by the applicant.

3) Expand the existing facility i.e. the current proposal.

A theoretical green field site was developed (on the assumption that such a site was available)

and it was deemed that a greater impact would be created by the siting of a 25,000 tonnes

Biodiesel facility on such a site.

Given the above and that the existing facility can accommodate the changes to facilitate the

additional 25,000 tonnes Biodiesel plant, it would seem logical that the development proceed

at this location.

An alternative site layout was initially proposed but following consultations with the owners of

Whitewood House it was deemed that this layout would potentially have a visual impact from

the protected structure. Therefore, the current proposed site layout was designed to ensure

that there is no visual impact.

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In addition, it was determined that the most sustainable option would be that which minimised

the tonne-kilometres to the greatest extent, i.e. the lower the number, the more sustainable

the option is in terms of truck movements and air emissions from vehicle movements. A

location close to a corridor link of cities and large towns would meet these criteria. By locating

in Meath, the subject development is not only in proximity to the Greater Dublin Area but also

the large towns in the North East Region and the Midlands Region. Subsequently a Greenfield

site was not considered appropriate when the above factors were taken into consideration.

The fact that the existing facility generates over 50% of the required raw material for the

Biodiesel plant on site makes it the most sustainable option.

As the existing processes use Best Available Technology there is no further need to look at

alternative processes.

The current proposal will provide a facility for the conversion of tallow, produced on site as

part of the rendering process, into Biodiesel. This will therefore eliminate the requirement for

this tallow to be transported offsite for further processing. The proposed development will also

provide a resource for the production of Biodiesel from tallow produced at other facilities.

The location of the proposed development in its current location between both the M3 and M1

Motorways will have the following advantages:

The existing land use policies for the site support the development of the subject

application and subsequently there are no non-conforming land uses immediately

surrounding the site. Most importantly the subject site is fundamentally suitable for the

location of the proposed development.

It is in close proximity to a large customer base from the North East Region, the

Midlands Region and from the Greater Dublin Area. The proximity of the M1/EO1 and

the M3 means ease of access from a significant customer base in addition to raw

materials generated from their indigenous processes.

Its location on the site of the existing facility will mean that existing infrastructure can

be utilised to maximum capacity with less need for major structural development.

The existing site already has good quality infrastructure in place such as services and

telecommunications to support the subject development.

1.3 Site Description

The subject site is located in the townland of College, Nobber, Co. Meath. It is situated

approximately 3km north of Nobber, a village on the R162 in north County Meath. Kingscourt

Co. Cavan, is a larger settlement lying approximately 11km north northwest of the site while

Drumconrath lies 6.0km to the east on the R165. The River Dee lies approximately 1.7-2.5 km

to the south and east.

The College Proteins site extends to approximately 19.24 hectares (47.5 acres) and is located

3 km north of Nobber, a village on the R162 in north County Meath (see Figure 3). The

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surrounding landscape is rural, comprised of grazing and arable lands, divided by frequent

mature hedgerows, and scattered with small farms and residential dwellings. The overall relief

of the surrounding area is dominated by drumlins.

These drumlins reach elevations of 100m O.D. and are generally small, approximately 200

metres across with a moderate gradient to the southeast. While lakes are frequently

associated with drumlin landscapes (and can be found elsewhere in this area), the local

landscape is largely devoid of them.

The site is also located within the River Dee catchment. There is a small stream draining the

area, which flows in a southerly direction discharging into a tributary of the River Dee at Creggs

Bridge.

Existing buildings on the site include a process building, an engineering workshop, a raw

material building, storage silos, bio-beds, maintenance workshops, a fully equipped

environmental laboratory, a quality laboratory as well as a large effluent treatment plant.

Figure 2 - Site Location Map

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Figure 3 - Detailed site location map

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Figure 4 - College Proteins Nobber Facility

1.4 Planning and Policy Context

The planning and policy context is addressed in the planning report prepared by Tom Phillips

and Associates Town Planners and gives an overview of the relevant legislation that supports

the subject development at a local, regional and national level.

1.4.1 National Framework Plan

The Project Ireland 2040: National Planning Framework (NPF) was published on 16th February

2018 and is the Governments high level strategic plan for shaping the future growth of the

country to the year 2040. It will guide public and private investment and create and promote

opportunities for people, and to protect and enhance the environment.

The NPF outlines key future planning and development place making policies is for the

Eastern and Midland Regions including:

“Harnessing the potential of the region in renewable energy terms across the technological

spectrum from wind and solar to biomass and, where applicable, wave energy, focusing in

particular on the extensive tracts of publicly owned peat extraction areas in order to enable a

managed transition of the local economies of such areas in gaining the economic benefits of

greener energy.”

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Having regard to Energy Production it is outlined that rural areas have significantly contributed

to the energy needs of the country and will continue to do so, ‘having a strong role to play in

securing a sustainable renewable energy supply’. In order to support the NPF, it will be

necessary to have:

“…further reductions in dependence on fossil fuels, moving towards wind, gas with carbon

capture and sequestration, biomass and other renewable sources.”

The proposed scheme to produce up to 25,000 tonnes of biodiesel per annum supports the

policies outlined in the NPF.

1.4.2 Regional Planning Guidelines

Regional Planning Guidelines (RPGs) were first adopted in March 2004 as a key

implementation mechanism of the Government’s overall framework for achieving more

balanced regional development and more strategic physical and spatial planning – the 2002

National Spatial Strategy (NSS). The principal function for RPGs is to link national strategic

spatial planning policies to the planning process at City and County Council level by co-

ordinating the Development Plans through the Regional Planning Guidelines.

1.4.3 Meath County Development Plan 2013-2019

The Meath County Council Development Plan is the statutory planning policy document for

the County and sets out the policies and objectives for the proper planning and sustainable

development of the County from 2013 to 2019.

The proposed development directly supports these polices and will help to achieve the

objectives outlined in the Development Plan as it will minimise the use of landfill through the

recycling and recovery of materials.

1.5 Environmental, Energy and Transport Policy

1.5.1 EU Policy

1.5.1.1 Introduction

European Union (EU) and Irish Government policies identify the development and promotion

of renewable energy, including Biodiesel, as a primary strategy in implementing national

energy policy. Presented below is a review of the policies and legislation, at international,

European, national and local levels, which relate to the development proposal at College

Proteins in Nobber.

1.5.1.2 The EIA Directive

The EIA Directive (85/337/EEC) is in force since 1985 and applies to a wide range of defined

public and private projects. The EIA Directive was amended in 1997, 2003 2009, 2011 and

2014 by Directives 97/11/EC; 2003/35/EC, 2009/31/EC, 2011/92/EU and 2014/52/EU. The

EIA Directive requires environmental impact assessments to be carried out for certain projects

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as listed in Annex I of the Directive. The EIA Directive, and amendments, are transposed into

Irish law through the Planning and Development Acts 1996 to 2017.

Under Schedule 5, Part 2, 6 (a) of the Planning and Development Regulations 2001 to 2018

an Environmental Impact Statement (EIS now EIAR), is required as part of the EIA process

to accompany Planning Applications for Installations for treatment of intermediate products

and production of chemicals using a chemical or biological process.

Directive 2014/52/EU (“the Revised EIA Directive”) was required to be transposed into

national legislation by 16th May 2017 however, at the time of submission of this EIAR,

transposition had not yet been completed. The Department of Housing, Planning,

Community and Local Government (“DHPCLG) has issued a consultation document

‘Transposition of 2014 EIA Directive (2014/52/EU) in the Land Use Planning and EPA

Licencing Systems – Key Issues Consultation Paper’ (“the Revised EIA Directive

Consultation”) which outlines how the Revised EIA Directive will be transposed into Irish

legislation. This document, in addition to DHPCLG July 2017 Circular Letter PL/1/2017,

dated 15th May 2017 “Implementation of Directive 2014/52/EU on the Effects of

Certain Public and Private Projects on the Environment (EIA Directive) – Advice on

Administrative Provisions in Advance of Transposition” (“the Revised EIA Directive Circular”)

have been used in the preparation of this EIAR.

Draft “Guidelines on the Information to be contained in Environmental Impact Assessment

Reports” published by the Environmental Protection Agency (EPA) in August 2017 detail the

key changes made by the amended 2014 EIA Directive. This document has also been used

in the preparation of this EIAR.

The Revised EIA Directive defines EIA as a process. Article 1(2) (g) states that EIA means:

“(i) the preparation of an environmental impact assessment report by the developer, as

referred to in Article 5(1) and (2);

(ii) the carrying out of consultations as referred to in Article 6 and, where relevant, Article 7;

(iii) the examination by the competent authority of the information presented in the

environmental impact assessment report and any supplementary information provided,

where necessary, by the developer in accordance with Article 5(3), and any relevant

information received through the consultations under Articles 6 and 7;

(iv) the reasoned conclusion by the competent authority on the significant effects of the

project on the environment, taking into account the results of the examination referred to in

point (iii) and, where appropriate, its own supplementary examination; and

(v) the integration of the competent authority's reasoned conclusion into any of the decisions

referred to in Article 8a”.

The Revised EIA Directive Consultation document indicates that the DHPCLG will adopt the

new definition in full in the transposing legislation, replacing Section 171A (1) of the Planning

Acts.

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The Revised EIA Directive requires the EIA to identify, describe and assess, in an

appropriate manner and in light of each individual case, the direct and indirect significant

effects of the Proposed Development on factors of the environment including:

(a) population and human health;

(b) biodiversity, with particular attention to species and habitats protected under the

Habitats and Birds Directives;

(c) land, soil, water, air and climate;

(d) material assets, cultural heritage and the landscape;

(e) the interaction between the factors referred to in points (a) to (d). The implications of the Revised EIA Directive in in relation to human health are considered in

Section 3.2: Population and Human Health of this REIS / EIAR; the implications in relation to

biodiversity are considered in Section 3.3: Biodiversity; and the implications in relation to

land are considered in Section 2: Project Description and Section 3.4: Soils and Geology’.

The implications in respect of water are considered in Section 3.5: Water, The implications in

relation to air are considered in Sections 3.6 Noise and Vibrations and Section 3.11 Air.

Material Assets are considered in Section 3.8: Material Assets and 3.9 Traffic. Cultural

Heritage is addressed in Section 3.10 Archaeology and Cultural Heritage. Landscape is

addressed in Chapter 3.12. The Interactions of the foregoing are considered in Chapter 3.13.

1.5.1.3 Kyoto Protocol to the Convention on Climate Change

In 1997, developed countries agreed legally binding targets in Kyoto to reduce global

emissions of six greenhouse gases by 5.2% in the first commitment period from 1990‐2012

and by at least 20% in the second period from 2013-2020. Ireland is a signatory to this

Agreement and has agreed to limit the growth in greenhouse gas emissions by 13% above

1990 levels. Through the agreement Ireland has agreed these quantified emission limitation

and reduction commitments in order to promote sustainable development. This includes the

development and increased use of new and renewable forms of energy. The proposed

development is compatible with the principles espoused in the Kyoto Protocol as generating

a high quality bio-degradable fuel such as Biodiesel will result in an environmentally clean,

alternative to conventional carboniferous fuels, thus reducing greenhouse gas emissions. On

a national level the use of biofuels is also considered to be carbon neutral under the Kyoto

Protocol, namely the quantity of carbon dioxide released by the combustion of plant derived

fuel is considered to be equal to the carbon dioxide absorbed during its growth cycle.

1.5.1.4 Animal By-Products Regulation 2002

In 2002 the European Parliament and the Council adopted EU Regulation 1774/2002 for the

handling of animal by‐products. This legislation, which came into force on 1st May 2003,

introduces stringent conditions and procedures throughout the food and feed chains which

require safe production, handling, storage and disposal of animal by-products. Regulation

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1774/2002 establishes a classification system for animal by‐products based on their potential

risk to animals, the public or the environment, and clearly sets out how each category must

be disposed of. The Regulation sets out three different categories which deal with all possible

waste material from animal by‐products. These are as follows:

Category 1 Material:

Material presenting the highest risk such as Transmissible Spongiform

Encephalopathies (TSEs)

Material containing residues of prohibited substances, such as hormones used for

growth promotion or environmental contaminants

SRM, including dead ruminants (animals which die without ante mortem checks, i.e.

fallen animals).

Category 1 material may be disposed of by incineration or co‐incineration. The Regulation

also provides for burial or burning in remote areas but only in emergency circumstances.

Category 2 Material:

Animal by‐products presenting a risk of contamination with other animal diseases (e.g.

animals which die on farm or are killed in the context of disease control measures on

farm)

Animal by‐products at risk of residues from veterinary drugs.

Category 2 material may be disposed of in the same manner as Category 1 material and it

may also be sent – provided it is subjected to the heat treatment prescribed – for processing

in either a Category 2 or oleo‐chemical plant or in bio‐gas and composting plants for

subsequent use as a land fertiliser. The spreading of such fertilisers on land is required to be

carried out in accordance with stringent conditions as specified in EC Regulations.

Category 3 Material:

Animal by products derived from healthy animals fit for human consumption in

accordance with community legislation but not intended for human consumption.

Category 3 material may be disposed of in the same manner as both Category 1 and Category

2 material and may additionally be used in the manufacture of pet food and in technical

products, provided it has been subjected to the proscribed heat treatment. Regulation

1774/2002 also lays down strict rules in relation to storage, transport and record keeping for

the handling of MBM. College Proteins has developed systems and procedures committed to

complying with these regulations.

1.5.1.5 The EU Emission Trading Scheme (ETS)

One of the key mechanisms introduced under the Kyoto Protocol is the international emissions

trading scheme which allows developed countries to trade their commitments. They can trade

emissions quotas among themselves, and can also receive credit for financing emissions

reductions in developing countries. The EU Emission Trading Scheme (ETS) came into

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operation on 1 January 2005 and was introduced to facilitate Member States achieve their

commitments to limit or reduce greenhouse gas emissions in a cost effective way. It is the

largest such scheme in the world and allows participants to buy or sell emission allowances

which means that emission cuts can be achieved at least at cost. The EU ETS is a 'cap and

trade' scheme, in that it caps the overall level of emissions allowed but, within that limit, allows

participants in the scheme to buy and sell allowances as they require. The cap makes sure

that CO2 becomes a product and, thus, CO2 is valued at a price, which is determined by the

supply and demand at the (trading) market.

Installations such as College Proteins which are part of the scheme are allocated a defined

number of emission allowances (from the cap). The allocation rules are defined Europe-wide.

One emission allowance equals one tonne of CO2. Once a year, each installation has to

surrender enough allowances to cover all its emissions. If a company reduces its emissions

so that it has more allowances than it needs, it can sell the remaining (not needed) allowances

at the market. Alternatively, it has to purchase additional allowances to comply with its

surrender obligation.

1.5.1.6 The Renewable Energy Directive 2009

The European Union Directive 2009/28/EC on the promotion of the use of energy from

renewable sources, also known as the Renewable Energy Directive (RED) is one of the most

important pieces of legislation influencing the growth of renewables in Europe and Ireland.

Statutory Instrument (SI) 147 gives effect to the RED in Irish law. The Directive establishes

an overall policy for the production and promotion of energy from renewable sources in the

EU. It requires the EU to fulfil at least 20% of its total energy needs with renewables by 2020

– to be achieved through the attainment of individual national targets. All EU countries must

also ensure that at least 10% of their transport fuels come from renewable sources by 2020.

The Renewable Energy Directive specifies that:

• Mandatory national targets should be established consistent with a 20% share of energy

from renewable sources in EU energy consumption by 2020. This is consistent with the

renewable energy target contained in the EU Climate and Energy package5 renewables

target. Ireland’s overall binding target is to ensure that at least 16% of gross final energy

consumption is from renewable sources by 2020 (compared with 2.8% in 2005).

• Each Member State must submit a national renewable energy action plan (NREAP) by

June 2010. Each Member State must also submit a report to the Commission on progress

in the promotion and use of energy from renewable sources by 31 December 2011 and

every two years thereafter.

• A mandatory national target should be established consistent with a 10% share of energy

from renewable sources in transport (RES-T) in EU energy consumption by 2020. The

10% target for energy from renewable sources in transport is set at the same level for

each Member State. This renewable energy can be from biofuels or the renewable portion

of electricity used for transport. The Renewable Energy Directive also establishes the

sustainability criteria for biofuels and bioliquids. Transport energy contributions from

wastes, second generation biofuels and electric vehicles (EVs) are given higher

weightings than first generation biofuels for the EU RES-T target.

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Amendments to Renewable Energy Directive are being considered at EU level at present with

regard to the use of biofuels towards meeting the RES-T and overall renewable energy targets.

The proposed amendments attempt to further encourage the transition towards advanced

biofuels in order to reduce competition between biofuels and food production and to mitigate

the potential for indirect land-use change emissions resulting from increased biofuels

production. The sectoral components of the overall 16% target are detailed in Table 1, which

outlines each form of renewable energy supply (RES). The current share of renewable energy

in these components is also presented.

Table 1: Target and Current Share of Renewable Energy in Energy Sector

Renewable Energy Supply Target Share 2020 2014 Position

Electricity (RES-E) 40% 22.6%

Heat (RES-H) 12% 6.7%

Transport (RES-T) 10% 5.6%

The Directive clearly recognises the high sustainability and significant potential of Biodiesel

made from animal fat and supports the development of this sector and the role proposals such

as the subject development can play in reducing greenhouse gas emissions.

1.5.1.7 The Fuel Quality Directive 2009

In April 2009, Directive 2009/30/EC was adopted which revises the Fuel Quality Directive

[Directive 98/70/EC] and sets technical standards for road transport fuels. It amends a number

of elements of the petrol and diesel specifications as well as introducing in Article 7a a

requirement on fuel suppliers to reduce the greenhouse gas intensity of energy supplied for

road transport (Low Carbon Fuel Standard). In addition the Directive establishes sustainability

criteria that must be met by biofuels if they are to count towards the greenhouse gas intensity

reduction obligation. It also increases the allowed Biodiesel content in diesel to 7% by volume,

with an option for more than 7% with consumer info. On the 02/02/16 The Minister for

Communications, Energy and Natural Resources published a draft order proposing that the

biofuel obligation increase to 8% with effect from 1 January 2017.

Growing biofuels on existing agricultural land can displace food production to previously non-

agricultural land such as forests. Because trees absorb CO2 from the atmosphere, removing

them for biofuel production may result in an increase in net greenhouse gases instead of a

decrease. In fact recent calculations in the context of the ISCC sustainability certification

process reveal that producing Biodiesel from animal fat achieves a remarkable 85% saving in

greenhouse gas emissions compared to fossil diesel fuel. This figure was confirmed by the

findings of a recent study by the Institute for Energy and Environmental Research (IFEU)

in Heidelberg.

To combat indirect land use change (iLUC), new rules came into force in 2015 which amend

the legislation on biofuels – specifically the Renewable Energy Directive and the Fuel Quality

Directive. On 28 April 2015, the European Parliament voted to approve new legislation, the

"iLUC Directive", which limits the way Member States can meet the target of 10% for

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renewables in transport fuels by 2020, bringing to an end many months of debate. There will

be a cap of 7% on the contribution of biofuels produced from 'food' crops, and a greater

emphasis on the production of advanced biofuels such as the subject proposal. Member

States must then include the law in national legislation by 2017, and show how they are going

to meet sub-targets for advanced biofuels.

1.5.1.8 The Seventh Environment Action Programme (2012-2020) (EAP)

The Seventh Environment Action Programme (EAP) will be guiding European environment

policy until 2020. In order to give more long-term direction it also sets out a vision beyond that,

of where it wants the European Union to be by 2050:

"In 2050, we live well, within the planet’s ecological limits. Our prosperity and healthy

environment stem from an innovative, circular economy where nothing is wasted and where

natural resources are managed sustainably, and biodiversity is protected, valued and restored

in ways that enhance our society’s resilience. Our low-carbon growth has long been decoupled

from resource use, setting the pace for a safe and sustainable global society."

It identifies three key objectives:

to protect, conserve and enhance the European Union’s natural capital

to turn the Union into a resource-efficient, green, and competitive low-carbon economy

to safeguard the Union's citizens from environment-related pressures and risks to

health and wellbeing

Four so called "enablers" will help Europe deliver on these goals:

better implementation of legislation

better information by improving the knowledge base

more and wiser investment for environment and climate policy

full integration of environmental requirements and considerations into other policies

The plan is a blueprint to transform the EU into a resource-efficient, low-carbon economy. It

has a special focus on turning waste into a resource, with more prevention, re-use and

recycling, and phasing out wasteful and damaging practices like landfilling. The EAP notes

that the benefits of a resource-efficient economy can be felt in many sectors. Environmental

technologies and services are a major success story, with employment growing at 3 % per

annum. The global market for eco-industries, currently valued at a trillion euros, is forecast to

double over the next 10 years. The programme entered into force in January 2014. The

subject proposal supports the policy framework of the EAP as its development will contribute

to securing sustainability in Ireland’s energy sector and will contribute to reducing our reliance

on imported fossil fuels.

1.5.1.9 The Paris Agreement 2015

Signed on the 12th December 2015 and agreed by 195 countries worldwide the Paris

Agreement is the first ever legally binding covenant of its kind. The universal agreement’s

main aim is to keep a global temperature rise this century well below 2 degrees Celsius and

to drive efforts to limit the temperature increase even further to 1.5 degrees Celsius above

pre-industrial levels. The 1.5 degree Celsius limit is a significantly safer defence line against

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the worst impacts of a changing climate. Additionally, the agreement aims to strengthen the

ability to deal with the impacts of climate change. It constitutes a major and promising step

towards building a low-carbon and climate-resilient world. The Paris Agreement provides a

long-term vision for developing new technologies such as the subject proposal and enabling

the transfer of these technologies from the developed to the developing world in order to help

nations mitigate and adapt to climate change.

1.5.1.10 The Resource Efficiency Roadmap

This is part of the Europe 2020 strategy for a smart, inclusive and sustainable economy in the

EU. It is one of the main building blocks of the resource efficiency flagship initiative and sets

out a framework for the design and implementation of future actions. As part of this process a

review of Waste Policy and Legislation is currently underway.

A primary objective is to develop new products and services and to find new ways to reduce

inputs, minimise waste, improve management of resource stocks, change consumption

patterns, optimise production processes, management and business methods and improve

logistics. The strategy intends to lay the ground work for more effective design of waste

legislation that promotes further the principle of the waste hierarchy to remove any ambiguity

and improve legal certainty, thus making legislation clearer, more effective and more easily

enforceable. The proposed facility is a key component of this strategy because it supports a

circular economy rather than traditional linear processes and will result in the production of a

valuable commodity i.e. Biodiesel increasing the longevity of the initial raw material of Tallow.

1.5.1.11 EU Waste Framework Directive and European Community (Waste Directive)

Regulations 2011

The Waste Framework Directive 2008/98/EC was applied on the 12th December 2010 and

introduced new provisions in order to boost waste prevention and recycling as part of the

waste hierarchy and clarifies key concepts namely, the definitions of waste, recovery and

disposal and establishes a legal framework for the treatment of waste both in Europe and

Nationally. The Waste Framework Directive (WFD) made it mandatory for member states to

implement a five-step waste hierarchy instead of the out dated six steps and obliges Member

States to move towards self-sufficiency.

Section 21(A) of the Waste Management Act has been amended by the European

Communities (Waste Directive) Regulations 2011 which updates the waste hierarchy which is

represented in Figure 5 below. In order of priority waste must be prevented, prepared for re-

use, recycled/composted, recovered (including energy recovery) or disposed. This proposed

development is in line with the new waste hierarchy.

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Figure 5: Waste Hierarchy 2011

1.5.2 National Policies

1.5.2.1 National Strategy on Biodegradable Waste

The National Strategy on Biodegradable Waste, published in April 2006 by DoEHLG, sets out

the Government policy for its diversion from landfill in order to achieve the targets as set out

in the Landfill Directive 1999/31/EC. This strategy is based on the key objectives established

in policy documents Changing Our Ways (1998), Delivering Change - Preventing and

Recycling Waste (2002) and Waste Management: Taking Stock and Moving Forward (2004).

The policy sets out a range of measures to meet diversion targets. The fundamental principles

of the strategy include:

"employing a combination of instruments to promote waste reduction – including

awareness measures, economic incentives, and regulatory measures;

continuing to develop an integrated waste system building on proposals and policies

in regional waste management plans and strengthening these where necessary;

emphasis on source separation of biodegradable wastes by the producer, followed by

separate collections by the collector, enabling high quality recyclables to be recovered;

striving to maximise the recovery of materials firstly, and energy secondly as a

sustainable means of treating waste, rather than diverting from landfill to other forms

of disposal; and

developing partnerships with other sectors (industry, agriculture, fisheries etc.)

enabling cost effective treatment systems to be established suited to Irish conditions".

The proposed development is in line with the National Strategy on Biodegradable Waste

through the proposed provision of an integrated and sustainable solution for the treatment of

Category 1 MBM.

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1.5.2.2 2006 Green Paper – Towards a Sustainable Energy Future for Ireland

The Green Paper Towards a Sustainable Energy Future for Ireland sets out the Irish

Governments proposals on delivering an energy policy for Ireland around the three pillars of

ensuring the security of Irelands energy supply, promoting the sustainability of Irelands energy

supply and enhancing the competitiveness of energy supply in Ireland. The green paper puts

forward policy targets and policy actions in order to achieve these aims and invites comments

from interested parties in order to shape energy policy in Ireland into the future. Following on

from the consultation process on this Green Paper, the White Paper Delivering a Sustainable

Energy Future for Ireland was published.

1.5.2.3 2007 White Paper- Delivering a Sustainable Energy Future for Ireland

The 2007 Government White Paper Delivering a Sustainable Energy Future for Ireland

articulated for the first time Ireland’s ambition for renewable energy, setting targets for 2020

of 33% of electricity from renewable sources with onshore wind providing the main

contribution; 12% renewable heat market penetration derived principally from bioenergy; and

at least 10% biofuels penetration in transport. An additional target was also set of 30% co-

firing with biomass at the three State-owned peat power generation stations, to be achieved

by 2015. Also in 2007, the EU set an ambitious renewable energy target as part of its overall

climate change and energy policies, with the objective of achieving 20% of all energy in the

EU from renewable sources by 2020. This was followed in 2008 by Ireland settling on a revised

ambition of 40% of electricity from renewable sources by 2020.

1.5.2.4 Waste Management (Food Waste) Regulations 2009, S.I. 508 of 2009

The Waste Management (Food Waste) Regulations came into force on the 1st of July 2010.

These regulations apply to a wide range of commercial premises where food waste is

produced including but not limited to restaurants, hotels, cafés, hospitals, schools, canteens,

shops, deli counters and local authority buildings. The regulations require that food waste

arising is source segregated and kept separate from non-biological waste and contaminants.

The regulations require that all food waste that has been source segregated at the producers

premises is subjected to an authorised treatment process at the premises where the food was

produced, collected by a permitted waste collector and transferred for an authorised treatment

process or transferred directly by the producer to an authorised facility for the purpose of an

authorised treatment process.

The purpose of these regulations is to segregate food waste in order to reduce the amount of

biodegradable waste being consigned to landfill in line with the targets set out in the EU Landfill

Directive and in the National Strategy for Biodegradable Waste 2006. In order to ensure the

successful implementation of these regulations a sufficient number of authorised facilities

need to be available. Without availability or sufficient capacity at these authorised facilities,

the dependency on landfill will continue.

1.5.2.5 Energy (Biofuel Obligation and Miscellaneous Provisions) Act 2010

Article 3 of the Renewable Energy Directive sets out mandatory national overall targets and

measures for the use of energy from renewable sources for all EU Member States. Ireland

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must ensure that its share of energy from renewable sources in all forms of transport in 2020

is at least 10 % of the final consumption of energy from transport. It is in the context of this

obligation that Ireland has implemented the Biofuel Obligation Scheme (BOS) which was given

effect in law by the Energy (Biofuel Obligation and Miscellaneous Provisions) Act 2010. The

Scheme is one aspect of a twin approach in meeting the EU target for the use of renewable

energy in transport; the second is to encourage the accelerated development and usage of

electric vehicles, for which the target is 10% of vehicles by 2020. Under this legislation, The

National Oil Reserves Agency (NORA) is the body charged with administering the BOS.

1.5.2.6 A Resource Opportunity-Waste Management Policy in Ireland 2012

This document was published by the Department of the Environment in July 2012 and sets

out the National Policy on waste management. It highlights the measures through which

Ireland will make the further progress necessary to become a recycling society, with a clear

focus on resource efficiency and the virtual elimination of the landfilling. This policy document

encompasses measures covering the full spectrum of waste management planning,

compliance and enforcement and charts a path towards a more modern, innovative and

sustainable approach to the management of our waste. There are three main guiding

principles outlined in this policy document which are as follows;

Firstly, we must place prevention and minimisation at the forefront of waste policy by

ensuring that we minimise the generation of waste through better design, through

smart green purchasing and through a keener awareness of locally produced goods

which boost jobs and the economy and can reduce impacts associated with

transportation;

Secondly, when waste is generated we must extract the maximum value from it by

ensuring that it is reused, recycled or recovered;

Thirdly, disposal of municipal waste to landfill must be a last resort – in fact, we must

now work to effectively eliminate our use of landfill for this purpose within the next

decade, in line with The 2011 EU Roadmap to a Resource Efficient Europe.

The document states that " all relevant Government Departments will work together to ensure

that policy and other supports are structured to encourage the provision of waste recovery

infrastructure, where appropriate".

1.5.2.7 Strategy for Renewable Energy 2012 -2020

The Strategy for Renewable Energy was published by the DCENR in May 2012 and sets five strategic goals for renewable energy as detailed in table 2 below:

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Table 2 Five Goals for Renewable Energy, Strategy for Renewable Energy, DCENR, 2012

1. progressively more renewable electricity from onshore and offshore wind power for the domestic and export markets;

2. a sustainable bioenergy sector supporting renewable heat, transport and power generation;

3. green growth through research and development of renewable technologies including the preparation for market of ocean technologies;

4. increasing sustainable energy use in the transport sector through biofuels and electrification;

5. an intelligent, robust and cost-efficient energy networks system.

Other key actions for increasing sustainable energy use in the transportation sector through

biofuels include progressively increasing the percentage levels of biofuels in the transport fuel

mix in line with the general biofuel limits outlined in the fuel quality directive and the EN

standards for vehicle fuels EU market developments generally and in consultation with all

stakeholders.

1.5.2.8 Draft Bioenergy Plan 2014

The Draft Bioenergy Plan was published by the Department of Communications, Energy and

Natural Resources (DCENR) in 2014. A Strategic Environmental Assessment and Appropriate

Assessment need to be completed before the plan can be formally adopted. This work is

already underway and is expected to conclude early this year (2016). Bioenergy has historically

been the largest contributor to Irish renewable energy through heat generation. It is expected to

continue to play a significant role in further displacing fossil fuels, especially in the larger heat users

in the commercial and industrial sector. The draft plan recognises that meeting the demand for

biomass from indigenous sources could deliver significant economic and employment

benefits.

The Plan seeks to form a link between critical policy areas for Ireland, namely, renewable

energy; agriculture; forestry; the environment; sustainability; and the growth potential of the

green economy; while taking account of international development policy considerations. The

plan states that ‘Bioenergy will be an essential element in contributing to Ireland’s future

energy needs, and has the potential to provide significant economic and environmental

benefits. Our available resource – derived from forests, wood processing by-products,

purpose grown energy crops, animal by-products, and waste – can rapidly increase through

supportive policies and actions across energy; forestry; agriculture; waste recovery; and

research, development and deployment’

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Figure 6: Potential Bioenergy Pathways

1.5.2.9 2014 Green Paper- Energy Policy in Ireland

The Green Paper on Energy Policy in Ireland recognises the important role energy security,

sustainability and competiveness play in driving economic activity. Cost-effective harnessing

of sustainable, indigenous, renewable energy resources is crucial to reducing our dependence

on expensive fossil fuel imports, improving our national competitiveness over time, reducing

harmful emissions and delivering growth and jobs in the green economy. These objectives are

fully aligned with those of EU energy policy, reflecting the common challenges faced by

Ireland, and our partners in Europe, in decarbonising our energy systems.

1.5.2.10 2015 White Paper -Ireland’s Transition to a Low Carbon Energy Future 2015-

2030

Following on from the 2014 Green Paper the Department of Communications, Energy and

Natural Resources (DCENR) published the recent White Paper which takes account of

European and International climate change objectives and agreements, as well as Irish social,

economic and employment priorities

This White Paper is a complete energy policy update, and sets out a framework to guide policy

between 2015 and 2030. Its objective is to guide a transition to a low carbon energy system,

which provides secure supplies of competitive and affordable energy. This national energy

policy framework has been developed in the context of the significant role played by European

institutions in determining energy policy, markets, and regulation. In relation to bio‐fuels, the

White Paper notes that a low carbon future involves increasing the national biofuels obligation

and improving take-up of zero and low carbon vehicles such as electric and natural gas

vehicles.

1.5.2.11 Agri‐Vision 2015 Action Plan

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The Agri‐Vision 2015 Action Plan was published by the Department of Agriculture, Fisheries

and Food in 2006, in order to aid the implementation of the Report of the Agri‐Vision 2015

Committee. In relation to bio‐fuels, the Action Plan notes that: “The agri‐food and forestry

sectors are the source of most renewable energy materials which can be transformed into a

range of environmentally friendly biofuels. Possible agriculture based raw materials include

oilseed rape, wheat and sugar beet (for liquid biofuels), forestry by‐products and other farming

and food processing by‐products such as meat and bone meal and tallow.”

The Action Plan sets out a number of reasons behind the growing strategic importance of bio‐

fuels. These are as follows: “Renewed attention has focused on the potential of biofuels due

to the convergence of a number of factors such as the increasing cost of oil, the volatility of oil

supply and the need to reduce carbon dioxide emissions.” In relation to Meat and Bone Meal

(MBM), the Action Plan recognises its value as a biofuel, noting that: “There are significant

opportunities for use of these by‐products as bio fuels. If successful, this would convert a

current cost to the agri‐food sector into a gain and also benefit the environment because of

the low emissions levels of CO2.”

1.5.2.12 The National Waste Prevention Programme (NWPP) Annual Report 2014

The National Waste Prevention Programme has been in existence since 2004. Led by the

EPA the aim of the NWPP is to deliver substantive results in waste prevention and

minimisation and to integrate a range of initiatives addressing; awareness raising, technical

and financial assistance, training and incentive mechanisms. The overall objective of the

NWPP is to establish an ambitious programme that delivers substantive results on waste

prevention & minimisation across both hazardous & non-hazardous waste arising’s.

The Programme has three main strands:

Production and consumption behavioural change - resource efficiency;

Statutory producer and holder responsibility obligations for specified materials and

substances; and

Measurement of progress through waste statistics reporting.

The NWPP issues annual reports outlining the progress made on waste prevention projects.

The most recent of these reports was issued in 2015 for the previous year of 2014. The report

provides an overview of the progress made by the NWPP in 2014 on a wide variety of

integrated projects focussing on waste prevention during the tenth year of the programme.

The report highlights the financial benefits of supporting environmental technologies and

‘builds on a concept known as the circular economy. Essentially this economic model puts

great emphasis on preserving products, components and materials in use for as long as

possible.

1.5.3 Local Policy

1.5.3.1 The Waste Management Plan for the Eastern-Midlands Region 2015-2021

Ireland is now divided into three regions for the purposes of waste management planning;

Eastern-Midlands, Southern & Connacht-Ulster. The Eastern-Midlands Region includes the

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local authorities: Dublin City, Dún Laoghaire-Rathdown, Fingal, South Dublin, Kildare, Louth,

Laois, Longford, Meath, Offaly, Westmeath and Wicklow.

The Eastern-Midlands Region (EMR) Waste Management Plan 2015-2021 provides a

framework for the prevention and management of waste in a sustainable manner in Meath

and the other local authority areas. Following a public consultation stage, the final Regional

Waste Management Plan was made on 12th May 2015.

The three key objectives of the Eastern-Midlands Region Waste Management Plan are:

Prevent waste: a reduction of one per cent per annum in the amount of household

waste generated over the period of the plan;

More recycling: increase the recycle rate of domestic and commercial waste from 40

to 50 per cent by 2020;

Further reduce landfill: eliminate all unprocessed waste going to landfill from 2016.

The plan adopts a circular approach by viewing waste streams as valuable material resources.

The plans notes that making better use of our resources and reducing the leakage of materials

as wastes from our economies will deliver benefits economically and environmentally of the

region. A strategic approach of the plan is to improve the recovery and generation of energy

by maximising the resource value of the materials and energy embodied in residual wastes

and further reducing the role of landfilling in favour of higher value recovery options.

1.6 Structure of the Environmental Impact Assessment Report.

Environmental Impact Assessment (EIA) is a systematic examination of the potential impacts

of a proposed development on the environment. College Proteins have been in operation at

this site since 1989. In assessing the Environmental Impacts this EIAR will evaluate the

existing situation and assess any potential impacts of the proposed development. Where

potential impacts are identified proposed mitigation measures will be identified. In addition the

in-combination effects of any other known plans or projects will be identified and assessed.

Under Schedule 5, Part 2, 6 (a) of the Planning and Development Regulations 2001 to 2018

an Environmental Impact Assessment Report (formerly an EIS), is required as part of the EIA

process to accompany Planning Applications for Installations for treatment of intermediate

products and production of chemicals using a chemical or biological process. In preparation

of this EIAR due regard will be paid to the following documents:

Environmental Protection Agency (2002) Guidelines on the information to be

contained in Environmental Impact Statements;

Environmental Protection Agency (2003) Advice notes on current Practice (in the

preparation of Environmental Impact Statements

Environmental Protection Agency (2015) DRAFT Guidelines on the information to be

contained in Environmental Impact Statements;

Environmental Protection Agency (2015) DRAFT Advice notes for preparing

Environmental Impact Statements;

The Revised EIA Directive Circular;

The Revised EIA Directive Consultation; and

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The draft EPA Guidance (2017).

The EIAR contains:

a description of the site and the existing environment,

information on the scale and nature of the proposed development

a description of the reasonable alternatives considered.

the environmental effects, if any of the proposed development.

impact assessment of the proposed development and mitigation measures to avoid,

reduce and where possible remedy significant adverse effects on the receiving

environment.

Monitoring measures where required and;

A non-technical summary

This Environmental Impact Assessment Report (EIAR) is arranged as follows:

Volume I: Non-Technical Summary

Volume II: Main Report

Volume III: Appendices

The existing environment and the subsequent impacts of the development are explained by

reference to its possible impact on the following environmental topics detailed in Table 3:

Table 3: Environmental Topics

Population and Human Health Biodiversity

Soil & Geology Hydrology and Hydrogeology

Noise Air

Climatic Factors Traffic

Cultural Heritage Landscape and Visual Impact

Material Assets including Traffic Inter-relationship between the above factors

Supporting documentation such as maps and relevant tables are appended to the EIAR.

The project team for the EIAR is detailed as follows:

Project Description – Jim Dowdall - Enviroguide Consulting

Population and Human Health – Gillian Free - Enviroguide Consulting

Soil & Geology – Claire Clifford M.Sc.of Enviroguide Consulting and Colin O’Reilly BAgrSc

PhD of Envirologic

Hydrology & Hydrogeology – Claire Clifford M.Sc.of Enviroguide Consulting and Colin

O’Reilly BAgrSc PhD of Envirologic

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Ecology – Joseph Adamson MCIEEM and Donnacha Woods M.Sc. of Enviroguide

Consulting.

Climate – Janet O Shea – Enviroguide Consulting

Air – Ian Crofts - Caulmert Ltd. Steve Frazer Airshed.

Noise & Vibration – Emma Finlay – Enviroguide Consulting

Design, Landscape & VI – Lorraine Fegan - O’Hagan & Associates.

Material Assets – Jim Dowdall – Enviroguide Consulting

Archaeology & Cultural Heritage – Dr Ellen O’Carroll

Traffic – Stephen Reid & Associates

1.7 Consultation and Scoping

1.7.1 Scoping Request

Scoping is the process of determining the content and extent of the matters which should be

covered in the environmental information to be submitted to a competent authority for projects

which are subject to EIA.

Scoping is conducted by contacting the relevant authorities and Non-Governmental

Organisations (NGOs) with interest in the specific aspects of the environment that are likely to

be affected by the proposed development. The organisations contacted are invited to submit

comments or provide information in relation to the proposed development that they may hold

or to highlight any issues that they feel should be addressed as part of the EIA. Consultations

will help ensure that all the impacts, issues, concerns, alternatives and mitigation which

interested parties believe should be considered in the EIA are addressed.

A scoping request which included details of the proposed development was prepared by

Enviroguide Consulting for and on behalf of College Proteins. This scoping request was

circulated to all identified relevant bodies on the 26th February 2016. All bodies contacted are

listed in Table 4 below. Scoping letters and responses are included in Appendix 1.

The scoping and contents element of the EIAR were determined following:

Existing knowledge of the site and surrounds based on current operations of the

existing facility;

Regard to 'Guidelines on the information to be contained in Environmental Impact

Statements' (EPA, 2002) and draft new Guidelines 2015;

Regard to 'Guidance on EIA Scoping' (European Commission, 2001);

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Consultation with various, relevant Statutory Bodies and Non-Governmental

Organisations.

A public consultation forum was held on 20th March 2018 in the village hall in Nobber.

A pre-planning application consultation meeting was held with Meath County Council on 12th

March 2018 to discuss the proposed development.

It should be noted that the scoping was carried out in relation to the previous application

which has been permitted and that therefore we did not request further comment on this

applciation/EIAR as it is essentially minor changes to the permitted scheme.

Table 4: Bodies Consulted During Scoping

Statutory Bodies Action by Enviroguide Consulting

Response Details

Inland Fisheries Ireland, Anglesea Street, Clonmel, Co. Tipperary.

Written scoping request sent on 26th February 2016

Written response received 14th March 2015

Department of Transport, Tourism and Sport, 44 Kildare St., Dublin 2

Written scoping request sent on 26th February 2016

No response received.

An Taisce, Tailors Hall, Back Lane, Dublin 8.

Written scoping request sent on 26th February 2016

Email response received on 1st March 2016.

The Heritage Council, Áras na hOidhreachta, Church Lane, Kilkenny, Co. Kilkenny

Written scoping request sent on 26th February 2016

No response received.

Health Service Executive, Environmental Health Service, St. Joseph’s Hospital Complex, Trim, Co. Meath.

Written scoping request sent on 26th February 2016

Written response received 12th March 2016

Health and Safety Authority, The Metropolitan Building, James Joyce St., Dublin 1.

Written scoping request sent on 26th February 2016

No response received.

Department of Arts, Heritage and the Gaeltacht, Johnstown Castle Estate Wexford.

Written scoping request sent on 26th February 2016

Written response received 12th March 2016

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Planning Department Meath County Council, County Hall, Navan, Co. Meath.

Written scoping request sent on 26th February 2016

No response received.

Environment Department Meath County Council, County Hall, Navan, Co. Meath.

Written scoping request sent on 26th February 2016

Email response received 16th March 2016

Department of Communications Energy and Natural Resources, 29 - 31 Adelaide Road, Dublin 2

Written scoping request sent on 26th February 2016

No response received.

Failte Ireland, 88-95 Amiens St., Dublin 1.

Written scoping request sent on 26th February 2016

Email response received 4th March 2016.

Geological Survey of Ireland, Beggars Bush, Haddington Road, Dublin 4.

Written scoping request sent on 26th February 2016

Written response received 10th March 2016

National Transport Authority, Dún Scéine, Harcourt Lane, Dublin 2.

Written scoping request sent on 26th February 2016

No response received.

The Department of Finance, Government Buildings, Upper Merrion St., Dublin 2.

Written scoping request sent on 26th February 2016

No response received.

The Department of Jobs, Enterprise & Innovation, 23 Kildare St., Dublin 2.

Written scoping request sent on 26th February 2016

No response received

Planning Department, Louth County Council, County Buildings, Dundalk, Co. Louth

Written scoping request sent on 26th February 2016

No response received.

Planning Department, Monaghan County Council, The Glen, Glen Road, Co. Monaghan.

Written scoping request sent on 26th February 2016

No response received.

Transport Infrastructure Ireland. St. Martin's House, Waterloo Road, Dublin 4.

Written scoping request sent on 26th February 2016

Written response received 31st March 2016.

Environmental Protection Agency, PO Box 3000, Johnstown Castle Estate, Co. Wexford

Written scoping request sent on 26th February 2016

No response received.

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Planning Department, Cavan County Council, Farnham St. Cavan

Written scoping request sent on 26th February 2016

No response received.

Office of Public Works, Jonathan Swift St. Trim, Co. Meath.

Written scoping request sent on 26th February 2016

Written response received 16th April 2016.

Waterways Ireland, Floor 2, Block C, Ashtowngate, Navan Road, Dublin 15.

Written scoping request sent on 26th February 2016

Written response received 29th February 2016.

An Bord Pleanála, 64 Marlborough St., Dublin 1.

Written scoping request sent on 26th February 2016

Written response received 7th March 2016

The Department Of Agriculture, Food and Marine, Agriculture House, Kildare St. Dublin 2.

Written scoping request sent on 26th February 2016

Written response received 18th March 2016

Irish Water Colvill House 24 – 26 Talbot St. Dublin 1.

Written scoping request sent on 26th February 2016

Written response received 18th March 2016.

1.7.2 Scoping Responses

This section of the EIAR presents a summary of the main points and recommendations that

were made in the replies to the scoping document as follows:

A general advisory note on the information to be supplied in an EIAR was submitted

by the HSE, TII, Failte Ireland and Irish Water.

Details such as storage of imported tallow, greenhouse gas emissions, odour impacts,

and the benefit of Biodiesel should be considered.

Examine if there will be any impact on material assets.

Address the potential impact on surface water and ground water especially in the

construction phase.

The Geological Survey have advised that Geological Heritage should be addressed in

the Soils and Geology chapter.

The Department of Arts Heritage and the Gaeltacht have recommended that the

applicant engages the services of a suitably qualified archaeologist to carry out an

Archaeological Impact Assessment in advance of the construction works.

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The EIAR should detail the management of by-products of the production process.

Recommendations that were made during the scoping process have been taken into account

and addressed where necessary within the contents of the EIAR.

Copies of all scoping responses received by the 28th June 2016 are included in Volume 3 of

this EIAR. Further scoping responses received after this date will be considered during the

operation of the proposed development, subject to the grant of consents.

1.7.3 Public Consultation

A public consultation was held in the village hall Nobber on Tuesday 20th March 2018 from

15.00 pm- 20.00 pm to discuss the details of the application with interested parties. The public

consultation was advertised in the Meath Chronicle newspaper, notices were displayed in

Centra Nobber, Pharmacy Nobber, Doctor’s surgery, Nana’s Kitchen Café Nobber,, Post office

Nobber, Weldons Hardware and McEntee’s Hardware Store, Nobber.

There were 11 people in attendance.

There was a positive reaction to the project from a number of people in relation to the

generation of 25 operational jobs and it was also deemed positive that the project would help

Ireland meeting their renewable energy targets by 2020.

Figure 7 Advertisement from Meath Chronicle (not to scale).

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