Make your voice heard and OBJECT to the planning application (again)

Ding ding! Round 2!

We have been contacted by many people asking whether they should submit comments on Acorn’s latest amendments. The answer is YES! The more people who respond to let the Planning Officer know their feelings the better. Your comments MUST be received by TUESDAY 21 NOVEMBER 2023.

If you objected previously then that objection still ‘counts’.  You could simply refer the planning officer to your previous objections but for the avoidance of doubt it is best to re-state your previously raised objections (this could be a summary of them) and make it clear that the amended application does not overcome your concerns.

The Proposed Changes Include:

• The number of annual HGV/Tractor vehicle movements has been increased to 24,566
• The size of the rainwater lagoon has been reduced slightly
• An extra ‘boundary’ line has been added outside the original site plan showing the landowner has control of the land between the site boundary and the stream and might therefore be able to discharge water from the site into it
• The lighting scheme has been updated to reduce ‘sky-glow’
• The planting scheme has been updated, with more tree cover and planting to increase biodiversity
• More details of the second access road directly onto Tysoe Road are provided
• For the Air Quality Assessment, the number of HGV movements during the 1-hour daytime assessment period has changed from 2 to 4 and for the the 15-minute night-time assessment period it is now 1
• The Biodiversity Net Gain report has been updated with new BNG figures
• Updated biogas and biomethane production figures have been given (slight change)
• A letter explaining adequate lightening protection will be provided (although it is not in the current plans).

Our Position

These minor changes do not alter the fundamental basis of the application, to build a massive, industrial gas plant with all its attendant traffic, odour, noise and light pollution, in open countryside, in full view of the Cotswold National Landscape and out of all proportion to any other development in the area.

The amendments are designed to mitigate some impacts a little but in NO WAY make the development acceptable.  The harm still far outweighs any meagre benefits and so the development contravenes the many planning policies designed to protect our community and our landscape.

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Arguments you may wish to consider in your comments on these amendments:

TRAFFIC

• The updated transport figures show that the site would require 24,566 annual HGV/tractor and trailer movements
• The existing average number of HGV movements per weekday on the A422 near the proposed site entrance was measured as 116 (not 125 as given in the Transport Statement).  The new statement says the site would generate an average of 70–84 HGV/tractor movements per day for 10 months of the year, rising to 202 at peak harvest times.  Enormous percentage increases on an already heavily burdened road, supplied by a network of small rural roads through villages
• The claim that much of this farm traffic is already on our roads is based on the anecdotal evidence of interested parties. If only ‘break-crops’ are being used to feed the digesters, most local farm traffic will continue as normal in addition to digester traffic.  All this traffic will now converge on one field, rather than being spread around the whole area
• As the applicant has requested that no limits be placed on any amounts of any feedstocks, market forces could increase this traffic dramatically
• The air pollution, noise pollution, danger, damage, and disruption caused by the huge volume of incremental traffic will be significant and harmful.

VISUAL IMPACT

• Some extra native, overwhelmingly deciduous, trees will take years to grow and even when fully mature will not ‘hide’ a vast complex of industrial structures, especially when viewed from higher viewpoints such as those within the Cotswold National Landscape, or in winter
• Whilst some colours may be chosen to try and ‘blend’ in with the countryside, the industrial, often reflective materials will be plainly visible
• Whilst the lighting has been redesigned, views from the Cotswold National Landscape still will be marred by light pollution as viewers will be looking down on the vast expanse of lighting, even without any ‘sky-glow’ 
• Any lightning masts will probably need to be taller than the digesters they are protecting and will be seen for miles
• ‘Panoramic’ imagery has been used, incorporating 4 photographs shot in portrait format, on a 50mm lens, and ‘stitched together’ and ‘cylindrically projected’ to form one very wide image.  This totally unnecessary procedure has resulted in misleading images that make the buildings appear much further away than they actually are, compared with the usual standard 50mm lens photo.

• By its use, processes, design, scale, massing, materials and siting the proposal would introduce a significant industrial development into this open countryside location, causing significant adverse effects to the Cotswold National Landscape even after 15 years.  This is despite the proposed mitigations, according to the updated Landscape and Visual Appraisal.

IMPACT ON THE ENVIRONMENT

• Whilst the proposed Biodiversity Net Gain actions increase opportunities for some forms of biodiversity they DO NOT compensate for the impact on the less common species in the locality such as brown hares, bats and curlews
• WCC’s Flood Risk Management Officer highlights the lack of clear drainage information.  The risk of contaminated run-off is especially concerning, as the site is in an SSSI Risk Zone and will drain into the adjacent watercourse, a tributary of the river Dene which flows onto Lobbington Hall SSSI.  The effects of ammonia from the site on the SSSI have not been assessed
• The Preliminary Ecological Appraisal (PEA) did not include the adjacent stream or the pond on the northern tip of the development, as the original site boundary lines were drawn just inside them.  The new boundary line includes that pond and the stream is now part of the drainage scheme of the site, so surely these should be included in the PEA
• The Great Crested Newt (GCN) Scoping Survey sometimes says there are 2 ponds within 250m of the site and sometimes 4 and it is not known at what time of year it was carried out.  As AD plants cannot be built within 250m of GCN this is crucial information, so is this a survey we can rely on, given the number of recorded sightings of GCN within 2km of the site?

IMPACT ON NEIGHBOURS

• The 6 dwellings that lie less than 300m from the proposed site will be affected by noise, odour and the constant worry of a catastrophic event like the recent explosion in Oxfordshire.  It is simply not good enough to say that as there are only a few of them, they don’t matter.  An industrial facility like this should NOT be built near ANYONE’S HOME.

CARBON CALCULATIONS

• Liquid Natural Gas or Liquid Petroleum Gas (both are mentioned) delivered by ‘no more than one tanker per day’ will be used to fuel the plant itself.  The carbon methodology uses figures for natural gas from the grid, but a grid connection is not possible here.  This will affect the carbon calculations.
• With Hazardous Substances Consent not yet confirmed at the Banbury Hub and likely to take 12 months to be decided, and the Newton Longville Hub application being recently withdrawn, it is not yet clear where the gas will eventually be injected and so carbon calculations will not be accurate.
• Neither the Arup Report or Acorn’s Carbon Calculations include the enormous carbon costs of building and decommissioning the site.  For how many years will the site need to be operational before it has offset these carbon costs?

MINISTRY OF DEFENCE (MOD)

• The proximity of large tanks of explosive gas next to an MOD munitions storage facility makes the issue of catastrophic explosion even more concerning.  The very high number of numerical errors and inconsistencies in documents throughout this application do not provide any reassurance that we would be in safe hands.

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IMPORTANT: ANY OBJECTIONS NEED TO REFER TO PLANNING POLICIES IN ORDER FOR THE COMMENTS TO BE VALID.

The planning policies include the impact on the landscape, particularly on the Cotswold Area of Outstanding Natural Beauty (AONB); the impact of traffic on the community and surrounding countryside; or the un-justified nature of such a large industrial plant being installed in the rural community where any benefit will be hugely outweighed by the harm caused by the plant.

Further information on planning policies can be found here: Why Say No?

• Please object individually, not as a family or a couple, we need NUMBERS, so if there are 4 in your family, send in 4 objections!
• Try to make all objections different – we were going to create a helpful template that you could copy and paste, but this would essentially make all the objections the same, therefore counting as one
• You don’t need to be a local resident to object – share far and wide with interested or concerned friends and relations

Alternatively, you can send an email to the Planning Case Officer, Joseph Brooke, at joseph.brooke@stratford-dc.gov.uk before TUESDAY 21st NOVEMBER 2023. You should include your name and address in your email. The planning application number is 22/02935/FUL.

Know someone who is not online? No problem, they can still object by writing a letter to: Joe Brooke, Planning Department, Stratford District Council, Elizabeth House, Church Street, Stratford-upon-Avon, CV37 6HX. Please make sure it gets posted with plenty of time!