The site for the proposed Anaerobic Digester (AD) is just under 2km from the nearest boundary of the Cotswold AONB (Area of Outstanding Natural Beauty), and clearly visible from it and is in the foothills of the site of the famous battle of Edgehill in 1642.

The proposed location is not a brownfield site – it is a greenfield site currently in farm production; it is not an industrial location.

The site is just over 2km north of Lower Tysoe, and 250m west of Hardwick House (Grade II listed) and the community of Hardwick Farm Barns. It is also 1.5km from the MoD Kineton weapons storage facility.

The Cotswold AONB is protected by statute and by policies in Stratford-Upon-Avon District Council’s own Core Strategy. The views to and from the Edgehill Escarpment are one of its special qualities and are legally protected. A huge industrial facility with all its ancillary infrastructure could not ‘conserve and enhance the natural beauty and landscape character’ of this National Landscape. How can the proposed development be satisfactorily integrated into the character and appearance of the villages and environs?

Building a large industrial plant would be almost criminally negligent in respect of the huge damage it would do.

If the development is allowed to go ahead, it would ruin the ancient and rural countryside in the area and intrude into the cherished views from the Cotswold AONB. It would be out of scale with the existing rural buildings in the area and become the dominant feature of the landscape.

Frankly, that’s devastating.

What will people heading to Shakespeare’s birthplace in Stratford-upon-Avon think when they see this huge industrial plant as they come down Sunrising Hill and cast their eyes over this ancient and rural part of England for the first time?

FOR A VIDEO OF A SIMILAR AD FACILITY SEE: https://youtube.com/watch?v=gtwcJ2m4fzE

What is Anaerobic Digestion?

Anaerobic Digestion (AD) is the process that mimics a cow’s stomach and breaks down vegetation.  Like a cow’s stomach the products are gas and slurry, which in the AD process, they refer to as ‘digestate’.  The digestate is pressed to separate the liquid digestate from the solids.  Like a cow’s stomach. The process needs to be run at around 35°C.

AD was supported in the early part of this century as a means of dealing with domestic food waste as an alternative to landfill Sites.  This site will not receive food waste and all feedstocks are specifically produced to support this production.

What are the gases produced?

The AD process produces mainly Methane [~60%], a hydrocarbon greenhouse gas, and Carbon Dioxide [~35% to 40%] which is another strong greenhouse gas.  The process can also produce other gases in smaller amounts such as hydrogen sulphide [smells like bad eggs and detectable by humans in concentration of as little as 0.01 to 0.3 parts per million parts of air (ppm)] which can be toxic and corrosive under certain circumstances. In concentrations of 1ppm to 10ppm it can cause nausea, irritation of eyes/create tears, cause headaches, and sleep loss.  In air concentrations of 10ppm to 150ppm it will cause further eye and lung irritation, and above 150ppm to 750ppm or above severe health effects and death.  The digestate storage lagoons may also emit ammonia which is heavier than air and can displace oxygen in the bloodstream.

What will happen to the gases produced?

Carbon Dioxide

The developer Acorn BioEnergy ltd say that they will separate out the carbon dioxide from the methane etc., and sell the carbon dioxide to food and drinks companies for aeration of food such as mousses and soft drinks.

Methane

The methane will be compressed and stored on site until delivered by road tanker to the Banbury gas terminal for injection into the mains supply.  First however it will be dosed with additional propane, another hydrocarbon gas so that when the mixture is burned it has a similar energy to Natural Gas.

Other gases

The other gases that are produced will be vented or will escape to the environment.

Will all the Methane be put into the Gas Mains?

No.  The site will burn 20% according to Acorn to heat the process, and to create electricity for use on site.  In addition the site vehicles, tractors, and HGV’s will be run off the production reducing the amount available to inject.

In summary

Ultimately the carbon dioxide will be released to the atmosphere after being consumed.  Methane will be used to power the transport vehicles which create more carbon dioxide and water vapour, as well as oxides of nitrogen from the atmosphere which are a cause of further health issues.

• The UK does not have a gas shortage according to HMG.  The price hike is Global Pricing, we have sufficient amounts of gas from the North Sea and Norway
• There is no carbon capture in this process
• The feedstocks are specifically grown to run the process taking land out of food production
• It would be far better to let the slow natural processes of decay work so that there is only a slow release of carbon back into the environment
• In short this AD plant is NOT GREEN and an opportunistic commercial development

This facility is much bigger than an on-farm facility – if it goes ahead, it will be one of the top ten largest Anaerobic Digestion Plants in the UK.

The site would cover 8.45 hectares – the size of nearly 12 football pitches; the five digester tanks with their plastic domes reach a height of 16.5m – or the height of 4 double-decker buses!

The storage lagoons for liquid digestate will contain 19,4660m3 of liquid waste – that is the same as 7 Olympic swimming pools!

Acorn say that they will screen this facility with trees and hedging… No amount of landscaping can possibly screen this.

Illustration showing the scale of one (of the five) digester tanks compared to double decker buses and an average person. Each digester tank is 16.5 metres tall and 34 metres diameter.

Hardwick Energy AD plant (Tubbs End) – site plan

Acorn insist that there will be “significant screening” in the form of native hedgerows and trees or other forms of vegetative screening. As many of us who live in this area know, plants and trees grow very slowly in our heavy clay soils, and their growth is affected because they do not thrive as they would in ideal conditions.

Proof of this is the woodland area of Hardwick Gorse – which can be seen on Google Earth as a plantation in 1999 – so it was planted over 23 years ago, possibly even 10 years before that.

Acorn say that “the site is well screened by existing, mature vegetation for minimum visual impact”.

Many trees in Hardwick Gorse, some of the “existing, mature vegetation”, are dead or dying, even hawthorns, which can survive in clay, are almost all dead or severely stunted. Any future plantings will struggle more than this due to climate change and extra dry conditions in the growing months, especially in bunds (elevated soil mounds).

And painting the proposed plant green as Acorn suggest, will not make five 16.5m digester tanks invisible!

Acorn state that the images captured for the LVA (Landscape and Visual Appraisal) carried out on their behalf, show deciduous trees when not in leaf. Acorn stress that this is worst-case in terms of views during the winter months. Let’s not forget that winter is 3 months of every year, and deciduous trees have little or no leaf for roughly 5-6 months every year. Vegetation is in full leaf, i.e., providing optimum screening conditions, for a maximum of 6 months a year.

The proposed facility will be very visible, not only to residents, but also to the many people who come to enjoy the Cotswold National Landscape – and it is likely to remain so for the entirety of its existence.

Yes!

Acorn have said they will import and treat 92,000 tonnes of feedstock – transporting all of this would cause a concentration of heavy farm and commercial traffic on the narrow, unclassified lanes around and through the surrounding villages of Tysoe, Kineton, Ettington, Radway, the Pillertons, Butlers Marston and Oxhill.

HGVs will be used, or agricultural tractor/trailers which could have an all-up permitted weight of 30 tonnes.

According to Acorn, ‘most feedstock related movements are redirections of existing farm traffic.’ To a degree this is true – but the traffic will be re-directed to focus on the AD plant, and so it will be concentrated on the narrow lanes in this area.

Traffic volumes will be concentrated on one new central location – it is not normal, local, agricultural traffic. Even this ‘redirected’ traffic is stated by Acorn to be 64% of the traffic generated by the AD, i.e. there will be an increase of 36% according to their own calculations. We think that this could be an understatement.

In addition, Acorn have not understood the current farming activities in the local area around the proposed AD plant – much of that land is permanent pasture (grass), grazed by sheep, and has minimal agricultural vehicle movements needed to maintain it.

There will be a devastating effect on road safety, noise, damage to roads and verges – and on the quality of life of local communities.

The vehicles from further afield will run on diesel, and local farm vehicles on red diesel, which will mean the release of further greenhouse gases into the environment – so not only are there increases in congestion, but also more pollution, as well as damage to the roadways which are not designed to take these loads.

There is no consideration in the planning application of the wider impacts of transporting feedstock and digestate, where the carbon emissions from the use of petrol – or diesel – powered vehicles are likely to be the highest ongoing carbon cost of the proposal.

Local farms are connected to the A422 by narrow, rural roads, and Acorn make non-committal statements about local farms supplying feedstock, but this does not identify how much will be sourced locally and how much will come from further afield.

Acorn insist that local villages, such as Tysoe, Kineton and Oxhill will be avoided – how can they guarantee to enforce this in practice?

The application does not identify the catchment area from which the feedstock will be sourced – so Acorn cannot know how much traffic there will be, or on which roads it will need to travel to reach the proposed AD. A commercial driver will, in any case, always choose the shortest route…

The carbon cost of transport has quite simply not been identified.

Transporting the gas to Banbury by road tanker along the A422 would cause more heavy traffic up Sunrising Hill, through Wroxton and Drayton and into Banbury. In poor winter weather, Acorn have a vague assumption (Tysoe Parish Council Meeting, 10 October 2022) that the gas would be transported in the other direction along the A422 to join the M40 north of Banbury. The congestion on the roads through Pillerton Priors, Ettington and Wellesbourne has clearly not been considered. Taking this route would increase the journey distance to 51km (102km accounting for the return trip)!

All this congestion, pollution, danger, and inconvenience to residents, would be intolerable

By the way, the A422 was proposed as an HGV designated route some years ago; this proposal was rejected by the Highways Agency as presenting too high a disruption for the villages along the route – since then traffic has only increased.

And did you know:

• Agricultural tractor/trailers do not require an MOT
• A 17-year-old, who has passed their car driving test, can legally drive a tractor/trailer with a gross mass of 31 tonne machinery on the road

We know that the digester will need 92,000 tonnes of feedstocks each year. To obtain this, Acorn will have to have a large catchment area – we think that this will mean larger traffic movements and more problems than admitted. The feedstocks could be imported from a radius of anywhere between 5km and 10km or more – no data is available on confirmed contracts for available land to supply the AD plant. The application suggests that the feedstock will come from the applicant’s farm and surrounding farms.

60% of the feedstock would be crops; one thing we do know is that maize and rye do not grow well around here.

The sources of feedstock should be identified, and it should also be demonstrated that these will be available for the duration of operation of the scheme.

Above all, we need to consider what will happen at harvest times when agricultural vehicles are usually working around the clock. Even Acorn recognise that there will be peaks of considerably more than double the average forecast daily traffic movements. This coincides with sunnier weather and school holidays to increase the hazards on rural roads – according to NFU Mutual, in harvest periods, road accidents already rise by 42%.

The additional heavy vehicle traffic movements would increase the risk to road users in a very rural environment and on already well-used roads.

Acorn provide limited information on the true impact of the traffic created by transporting the digestate from the digester to farms. Solid digestate cannot be spread on fields all year round – typically it is spread between late winter and the end of summer, at most 7 months per year. These trips to transport the digestate would therefore be concentrated into a shorter period – 30 weeks rather than 52 weeks, again leading to an increase in vehicle movements in that period.

Acorn say that the data in table 6-2 (p29) of the Transport Statement has been compiled ‘following a detailed assessment which has included liaising with local landowners and farm operators to forecast typical feedstock supplies’. Again there are no details of who they have liaised with – we have spoken to several farmers in the Tysoe area who have not been approached by Acorn.

See: Adam Wyatt, EngTech MIAgrE: ‘TRANSPORTATION USING AGRICULTURAL TRACTORS/TRAILERS TO MOVE DRY PRODUCTS AND LIQUID WASTE IN AND OUT OF THE PROPOSED AD PLANT AT HARDWICK ENERGY’

Acorn Bioenergy Ltd. have stated in their EIA Screening Report, that the proposed AD plant is safe, assuming correct operation and maintenance. However, there have been several incidents including damage to the operating plants, the environment, and explosions resulting in the death of employees and contamination of the environment.

The Environment Agency published an Incidents Report: ‘A Review of Environmental Incidents at Anaerobic Digestion (AD) Plants and Associated Sites between 2010 and 2018‘ of the AD industry in 2019 showing examples of incidents caused by poor maintenance and lack of understanding. According to Biogas World, there were about 800 accidents on biogas plants in Europe between 2005 and 2015, and examples of UK incidents can be found in this report.

NNFCC (The Bioeconomy Consultants & DEFRA – The Official Information Portal on Anaerobic Digestion) state, ‘Anaerobic digestion can be regarded as a chemical process with all the associated risks… Therefore, it is essential that thorough hazard and risk assessments are carried out at each stage of a project, from design to installation, to commissioning, to implementation and operation.’

A Health and Safety Plan including training and maintenance has not been referred to in the EIA Screening Report.

Farm-Energy noted in 2019 that, ‘Overall, biogas risks include explosion, asphyxiation, disease and hydrogen sulphide poisoning. Extreme caution is necessary when working with biogas.‘

Examples of AD plant accidents and explosions can be found all over the internet:

• In an explosion at Harper Adams University in 2014, the surrounding land was showered with tons of toxic slurry
• Fifteen months later a processing tank at the AD plant is believed to have collapsed at Egremont, near Newport, Shropshire.
• Two men were seriously injured after an explosion at an AD facility in 2017
• Tragically, in 2020 an explosion at an AD water treatment plant resulted in 4 deaths
• In 2007 a huge explosion destroyed the AD in Daugendorf, Germany. The alarm was raised at 4.20am when, for unknown reasons, a 20m high and 17m wide digester tank exploded, showering the contents of the digester over an area of roughly 200m around the site.  Nearby buildings were badly damaged. Luckily no one was killed. The article linked here is in German, but the pictures say it all. This site is significant because of the concrete construction of the digester tanks similar to those proposed by Acorn at the Hardwick Energy site.
• A digester at Wallingford’s Agrivert AD plant was struck by lightning in June 2016, causing a short but intensive fire at the biogas plant. The incident has led to warnings from AD sector experts over potential safety hazards. An organic waste specialist said that the incident should serve as ‘a sober lesson on the hazards associated with AD plants and the storage of biogas’. Thankfully people weren’t injured and Agrivert appear to have emergency plans in place, but can this be said of all AD plants?

The potentially high level of risk associated with this operation suggests that the 5 plant employees will require specialist training – it is likely that they will not be recruited from the local working population.

There is no reference to an emergency services plan in case of accident or incident.

At the Tysoe Parish Council Meeting on 10 October 2022, Acorn representatives told us that the proposed industrial plant would not have 24-hour security. There will be a supervisory control and data acquisition (SCADA) system monitoring the facility overnight when it is not manned.

Surely a gas plant storing methane and liquid waste, where an explosion, fire or leak could result in deaths or contamination of the environment should be monitored around the clock?  – particularly when that plant is only 1.5km from the UK’s largest munitions’ depot?

To sum up – there may be a low risk of failure, but the consequence of failure would be catastrophic.

The digester is a closed and controlled process and Acorn tell us that dry decomposing does not smell – ‘this is not a food waste/sewerage plant, so avoiding the issues of odour prevalent with this kind of AD’, but they also admit that there will be ‘potential for odour and bio-aerosol emissions’ from waste materials and from the process itself.

Equally by admission, the plant will be operating 24/7 and discharges, poisonous or just smelly, will carry into the local atmosphere.

Tysoe residents know that the unpleasant smell from the food processing plant in Banbury can, in certain weather conditions, be picked up in Tysoe which is about 10km away. Acorn are minimizing a problem that is well reported and documented.

People living close to ADs in other areas of the UK have reported bad smells that make their eyes burn and run, and their throats hurt.

Numerous reports in the media describe the odours as:

•  ‘Unbearable’ and ‘nauseating’
•  ‘Unpleasant’
•  ‘Sewage-like’, ‘very, very bad’
•  ‘Like a combination of dogs’ muck and burnt plastic’

What if we can’t use our gardens or open our windows in hot weather? What about our well-being? Why should our lives be blighted by such an industrial installation.

The plant will be operational 24 hours, seven days a week. It will be staffed 07.00-19.00 Monday to Sunday. ‘Except during peak harvest periods when working hours would be extended as necessary’. Vehicle movements Monday to Friday 07.00 – 18.00 and Saturday 07.00 – 13.00.

Deliveries of crops to the site would be determined by the harvest. Harvests are ordinarily completed on a campaign basis, therefore during peak harvest periods, delivery hours would be in line with standard agricultural harvest-time activity.

Export of the bio-methane would take place once every 10 hours, including overnight.

Construction activities would be Monday – Friday 07.00 – 19.00, reduced hours (not specified) on a Saturday. No construction to be undertaken on Sundays or Bank Holidays without prior approval, unless in the case of emergency.

Putting a large, industrial plant, as proposed, on a greenfield site would have a huge impact on the environment and local ecology.

If the plant goes ahead, these effects will be irreversible.

There will be pollution, disturbance, and potential destruction, not only by the operations of the AD itself, but also by its minimum 70 week construction programme.

The proposed development sits in a landscape known to be an important stronghold for many threatened farmland birds – we particularly need to mention the importance of the area for breeding curlews: this is their most important remaining stronghold in Warwickshire.

In addition, Great Crested Newts have been found in several locations within 2km of the proposed site. Great Crested Newts are strictly protected under the Conservation of Habitats and Species Regulations, as well as the Wildlife and Countryside Act.

The site will create light pollution which disrupts ecosystems and is a threat to nocturnal wildlife and birds as it confuses animal navigation. Nighttime light can also impact insect reproduction and development. There will also be light pollution from the increased traffic – deliveries will not stop when it gets dark. In the winter months, it will get dark several hours before the plant closes. If there is 24hour security of the plant, as for safety reasons there should be, that will mean lighting throughout the night.

Any development of this size and in this location illuminated during the hours of darkness is at odds with the tranquility and dark skies policy of both the Cotswold National Landscape Board and the CPRE, as well as the NDP’s own policy (Natural Environment Policy 2).

The Sun Rising Natural Burial Ground and Nature Reserve – ‘a place of deep natural peace’ – reflects this tranquility – and is less than 2km from the site.

The area is rich in history – close to the site of the Civil War Battle of Edgehill.

It has a history of human occupation dating back to about 10,000 BC.

The origins of our villages date back to medieval times, and earlier.

The built heritage is found in 6 Conservation Areas, and 190 Listed Buildings within a 4km radius – one of these near to the site itself. This listed building, Hardwick House, 300m from the proposed site, likely contains within the property boundaries the deserted medieval village of Hardwick – home to 70 people in the 13th Century.

The countryside within which this development would sit contains narrow lanes popular with cyclists, as well as a network of well-used local footpaths – such as Centenary Way and the MacMillan and ancient Jurassic Ways, which follow the escarpment on the edge of the Cotswold National Landscape, and from where the AD plant would be visible – not to mention the popular Edgehill Battlefield Trail, 2.5km to the north-east.

The application for the digester takes a very basic view of this environment and chooses to limit its impact within an arbitrary radius of 1km. In planning terms this would be normal for a small development, but a construction of this magnitude needs to be seen in a wider landscape context. The application bases its concept of ‘history’ almost entirely on designated sites and buildings (of which there are few within 1km) thus avoiding assets which lie just beyond.

The whole area is recognized in the Tysoe Neighbourhood Plan as one of cherished natural beauty, and the proposed site lies well outside the agreed boundaries where development might take place.

An industrial plant covering 8.45 hectares with a height of 16.5m is completely incongruous to this historic setting and will damage the character and distinctiveness of the area. 

Many of the key planning policies relevant to this application presume that a development may be acceptable if it can be demonstrated that the benefits it provides outweigh the harm that it might do.  These include local and national planning policies (SDC Core Strategies; National Planning Policy Framework). Several also argue that the benefit should be local.

Contrary to what Acorn say in their Landscape and Visual Appraisal, the nearest homes to the proposed site are at Hardwick Farm Barns, about 250m from the site. The Grade II listed Hardwick House is 300m from the site. There are other houses and farms within 1000m, and Upper Tysoe is 4km away.

According to Acorn, ‘the closest properties to the Proposed Development are a few farms within a 2km radius of the site. These include Hardwick and Brixfield Farms to the east (near representative viewpoint 1).’ For information – ‘representative viewpoint 1’ is taken from one of the garages belonging to a property at Hardwick Farm Barns. The garages are separate from the dwellings, and the views are not at all representative of the views from the homes themselves.

There will be a very negative visual impact on the people who live in homes immediately next to the proposed plant – at curtilage listed Hardwick Farm Barns and the Grade II listed Hardwick House. Residents living here will also experience continuous smell and noise and be first in line for any toxic leakage.

According to Acorn the plant will be illuminated during the hours of darkness despite being in a ‘dark skies’ area. Light, smell and noise pollution would have a significant if smaller impact on over 4000 residents, schools, recreational areas, and small businesses within a 4km radius. 

So, the effect of this AD will be much more far-reaching: it will be a blight on the area for several kilometers.

The impact on the landscape will be significant and detrimental. We see the harm caused to the environment by the proposal as vast and catastrophic. The setting is not a brownfield site, and Acorn have admitted at the Tysoe Parish Council meeting on 10 October 2022 that they had not considered brownfield sites! Obviously, it is in the best interests of all of us to address the climate crisis, but more suitable sites for this kind of industrial plant should surely be explored!

The Cotswold AONB lies less than 2km away, and this area is ‘a cherished landscape’ as defined in the Tysoe Neighbourhood Development Plan. The huge industrial gas-producing facility proposed on a productive, arable greenfield site will be hugely visible from a wide area and harmful to existing cherished views.

The contribution that the proposal would make to the national renewable energy generation targets is small, while the harm it would cause to the Cotswold AONB and Special Landscape Areas is unacceptable and irreversible.

The villages and fields in this landscape have developed gradually from medieval times, and there is evidence of prehistoric, Iron Age and Roman sites, as well as a deserted medieval village at Hardwick itself.

The area provides a natural sanctuary for threatened species such as curlews and great crested newts. Think of the harm and disturbance to our local wildlife and historic landscape by the plant and its lengthy construction.

There are serious concerns regarding increased traffic, congestion, and pollution throughout the neighbourhood, as well as safety on the roads, particularly near villages and schools, and danger to cyclists, horse-riders, and pedestrians.

These villages include Tysoe, Oxhill, Kineton, Radway, Ettington, Pillerton Priors, Pillerton Hersey and Butlers Marston. More than 4000 people live within a 4km radius of the proposed site.

Acorn argue that the digester will produce 20,466,506 Nm3 of biogas per annum, enough, they say, to power 7920 homes. However, only 80% of this will be pumped into the gas main. Despite the size of the plant, its actual contribution to the UK’s energy resources is tiny.

Apart from generating methane, the plant produces ammonia and hydrogen sulphide. The liquid digestate which is toxic is held in tanks the size of nearly 8 Olympic swimming pools. The Environment Agency has reported on problems of seepage into water courses (the site is next to a natural spring), and of the release of ammonia and hydrogen sulphide into the atmosphere. We must ask ourselves questions about safety, especially as the digester process runs 24/7, but the plant will only be manned during the working day. As the proposed plant would be a potential bomb due to the methane and propane stored on site, as well as the methane in the digesters, remote monitoring via SCADA is not sufficient to protect such a vulnerable facility in a remote location.

Any pollution caused by chemical leakage would be massive and irreparable to the local environment and ecology and detrimental to the lives of people who live nearby.

Stratford District Council’s Core Policy CS3 states that any development of this type must have a positive benefit locally, irrespective of the development’s importance nationally.

• The plant will employ 5 staff – but at least one of these is a specialist position and may well be recruited from outside the area
• ‘Maintenance workers at the injection hub’ – which is in Banbury, in the neighbouring county…
• ‘100 temporary construction jobs’ – whoever constructs this plant will already have a workforce that they will, likely, simply contract into site. But there may be some opportunity for hiring temporary local labour
• Local shops and businesses in Tysoe and Kineton may enjoy some temporary economic benefit
• There will be a benefit to farms that agree to a long-term supply contract for feedstock for the digester, as they can plan for cropping over the medium term and have the possible security of a guaranteed margin on that crop
• There will be a supply of digestate that local farmers can buy to put on their fields. However, digestate is already available to farmers from several sources
• Finally, Acorn have told us, rather insultingly, that we will benefit from ‘educational visits’… Given the toxic and flammable nature of digestate and methane respectively, it would seem unnecessarily risky to take groups of school children – local or otherwise – on visits to the AD!

However, the product of the AD, biogas, will be transported to Banbury and pumped into the national grid. There is NO BENEFIT from this for residents in this area who within a 5km radius of the proposed site have no access to the gas mains.

Has the size of the proposed site been determined to meet a subsidy threshold? It has certainly not been determined based on locally available feedstock. The problem with the size, as discussed, means that the volume of feedstocks required to feed the plant results in feedstock being transported long distances at a high carbon cost – which reduces and could possibly even outweigh the carbon savings of the scheme. Local farms will only provide a part of this feedstock requirement.

Taking any productive arable land out of food production to provide crops for decomposing in a digester is outrageous given current supply issues and constantly rising prices.

Overall, the proposed development will reduce the health and wellbeing of the local population and existing commercial activities. There would be damage to the environment and the quality of life of those who live in the neighbourhood. There is no benefit here to the local community.

In their EIA Screening Application (p18, Section 5.9, ‘Socio-Economics’), even Acorn admit the following:

‘The temporary increase in employment and the associated secondary economic effects such as supply chain multiplier effects, and spend on local services, would have a positive effect at a local level during the construction phase. However, this would reduce to a modest and insignificant effect during operation.

There would also be a beneficial though not significant effect on the local farming economy due to sustainable use of agricultural wastes and the production of digestate for use as an artificial fertiliser replacement. 

Overall, the local economic effects are unlikely to be significant in the long-term.’

All profits will be taken by Acorn’s Spanish investors and there will be no financial benefit locally.

If the plant does not make adequate profit and becomes non-viable, the planning application describes no plans for decommissioning – so Tysoe and the neighbourhood will be left with a large, redundant industrial plant which really would cause long-term harm.

Any small benefits of this proposal would be outweighed by the great harm it would do to this area.

Tysoe’s benefits will be in the form of a wrecked landscape, noise and light pollution, risk of chemical contamination, ruined views and tranquility, damaged ecology, and traffic chaos.

Acorn Bioenergy is committed to developing a portfolio of biomethane injection facilities – in fact, according to one of Acorn’s investors, P3P, Acorn Bioenergy ‘has the potential to build out one of the largest biomethane portfolios in the country’ (Alex Bartho, P3P Partners LLP – www.p3ppartners.com.)

Acorn is privately held, private equity-backed, and is a for-profit company. It is a young company founded in 2019 as P3P Partners LLP dedicated anaerobic digestion business. How many AD energy installations have Acorn Bioenergy built to date and run? They are a start-up company with no track record.

Acorn has secured a generous UK Government subsidy in the form of Renewable Heat Incentive. This is a 20-year, inflation-protected income stream, approved by Ofgem.

In September 2022, the Spanish fund manager (focused on renewable energy), Q Energy, acquired an 85% stake in Acorn Bioenergy for an undisclosed sum. At this point, P3P Partners LLP ceased to have significant control, and are now minority shareholders only.

By admission at the October meeting of Tysoe Parish Council, despite using UK Government subsidy for the AD, all profits from the proposed gas plant would go outside of the UK, to Spain.

There are several planning decisions, made by Stratford on Avon District Council, that provide precedents for this application.

• A proposal (16/01490/FUL) for a smaller AD plant in Alderminster was rejected by SDC in 2016 as being contrary to SDC’s Core Strategy, “to CS.3, CS.5, CS.9, CS.121 and AS.10 Core Strategy 2011 – 2031, and paragraphs 7(5), 98, 109 of the NPPF.”

Planning application 16/01490/FUL was rejected (see refusal letter here) on the following grounds:

The proposed development, by virtue of its size, height, bulk, mass and intensity, would be visible within the landscape including from within the Feldon Parkland Special Landscape Area (SLA) and further afield in views to the SLA. There would be an apparent impact on the landscape character of the site and consequently on this part of the SLA.

The proposal is not considered to maintain or enhance landscape quality and it would not safeguard, manage or promote the special attributes and key qualities of the SLA designation acceptably (as described in the Stratford on Avon District Special Landscape Areas Study 2012). Therefore the proposal is harmful to the distinctive character and appearance of the SLA.

Whilst measures have been proposed to protect landscape quality (including landscaping around the site), and it is also considered that the proposal would secure a number of benefits which are in the wider public interest, these factors are not considered sufficient, individually or cumulatively, to outweigh the identified harm. As such, it has not been demonstrated that the impacts are, or can be made, acceptable.

The proposal is therefore contrary to Policies CS.3, CS.5, CS.9, CS.12 and AS.10 of the Stratford on Avon District Core Strategy 2011-31 and paragraphs 17(5), 98 and 109 of the NPPF.

We believe that there are strong parallels with our application 22/02935/FUL.

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• Application for a 12,000-bird free-range egg production unit in Lower Tysoe.

Planning application 03/02381/FUL for an egg production unit in Lower Tysoe, north of the settlement and south of the A422 was rejected at appeal (see appeal decision here) for the following reasons:

The proposals relate to the erection of a large building in an area of undeveloped and flat landscape characterised by few buildings or structures of any sort. Because of this undeveloped character which gives the area a sense of rural remoteness the building would be a dominant and discordant feature. The building would be seen as an uncharacteristic feature in the landscape when viewed from the public footpath known as Centenary Way located on the top of Edge Hill within the Cotswold Area of Outstanding Natural Beauty. The proposal would therefore be harmful to people’s enjoyment of the AONB in the area of Edge Hill.

The site of this application is approximately 1,200m from the proposed digester site of application 22/02935/FUL. We believe that this decision demonstrates that the views from the AONB are valued and any potential damage that would arise from an application should be weighed against any benefit accruing from the application.

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• Proposal to erect 4 wind turbines on land between Bishops Itchington, Gaydon and Knightcote.

Planning application 12/00330/FUL was refused by SDC and was appealed by the applicant (see appeal and other decisions) with the appeal eventually considered by the Secretary of State who rejected the appeal on grounds including, inter alia, the following:

……..[the Inspector] finds that the proposed turbines would appear dominant and overbearing……..

…….With respect to the public visual impacts of the proposed turbines identified in IR10.46 the Secretary of State agrees with the Inspector’s conclusion that these would be very significant and adverse.

…..The Secretary of State agrees with the Inspector’s conclusion at IR10.49 that the impact of the proposed turbines would materially and unacceptably reduce the amenity value of the Country Park and the public’s enjoyment and use of it.

Although some of these comments are site and application specific, they demonstrate that the harm done to the amenity and landscape value of the surrounding countryside, especially when protected as in a Country Park (or an AONB) is to be taken into consideration and weighed against any benefit that might accrue from the proposal.

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And lastly –

• White’s Renewable Energy Landscape Sensitivity Study for SDC (2014), which considers the suitability of the Feldon Vale Farmlands for solar and wind farms, states the potential for solar energy development is limited to areas ‘away from the many views from surrounding higher ground, especially the adjoining Cotswold AONB and along Edgehill’.

It also says areas close to Edgehill battlefield and listed buildings and their setting are ‘sensitive and  unsuitable’.

This proposed AD development would be much taller and far more visually intrusive than a solar farm of similar footprint.