Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning, Design and Access Statement
662939
DECEMBER 2020
RSK GENERAL NOTES
Project No.: 662939
Title: Castle Eaton AD Plant Upgrade and Extension, Planning Design and Access statement
Client: Biomethane (Castle Eaton) Limited
Date: December 2020
Office: Manchester
Status: Final for Planning
Technical Author Poppy Grange reviewer Sydney Hougrand
Signature: Signature: Date: 23.12.2020 Date: 23.12.2020
Project Manager David Conway
Signature:
Date: 23.12.2020
Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
CONTENTS
1 INTRODUCTION ...... 1 1.1 Background ...... 1 1.2 The Planning Application Submission ...... 1 1.3 Structure of this Statement ...... 2 2 SITE DESCRIPTION ...... 4 2.1 Site Location ...... 4 2.2 Site Description and Existing Operations ...... 4 2.3 Site Access ...... 5 3 ENVIRONMENTAL BASELINE ...... 6 3.1 Access and Trip Generation ...... 6 3.2 Landscape ...... 6 3.3 Ecology ...... 7 3.4 Arboriculture ...... 8 3.5 Cultural Heritage...... 8 3.6 Ground Conditions...... 9 3.7 Flood Risk and Drainage ...... 9 3.8 Noise ………………………………………………………………………………………………..10 3.9 Odour ………………………………………………………………………………………………..10 3.10 Public Rights of Way ...... 11 3.11 Planning History ...... 11 4 THE PROPOSED DEVELOPMENT ...... 14 4.1 Overview ...... 14 4.2 Layout ………………………………………………………………………………………………..14 4.3 Scale ………………………………………………………………………………………………..15 4.4 Design ………………………………………………………………………………………………..16 4.5 Use ………………………………………………………………………………………………..16 4.6 Need for the Proposal ...... 17 4.7 Project Benefits ...... 19 5 PLANNING POLICY CONTEXT ...... 20 5.1 Energy White Paper ...... 20 5.2 Online Planning Practice Guidance: Renewable and low carbon energy ...... 20 5.3 National Planning Policy Framework ...... 21 5.4 Local Planning Policy ...... 23 6 ENVIRONMENTAL CONSIDERATIONS ...... 26 6.1 Introduction ...... 26 6.2 Transport and Access ...... 26 6.3 Landscape and Visual ...... 26 6.4 Ecology ...... 26 6.5 Arboriculture ...... 28 6.6 Cultural Heritage...... 28 6.7 Ground Conditions...... 29 6.8 Flood Risk and Drainage ...... 30 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
6.9 Noise ………………………………………………………………………………………………..31 6.10 Odour ………………………………………………………………………………………………..31 7 CONCLUSION ...... 33 APPENDIX A – COUNCIL PRE-APPLICATION RESPONSE ...... 34 APPENDIX B – POLICY ASSESSMENT ...... 35
Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
1 INTRODUCTION
1.1 Background
1.1.1 This Planning and Design and Access Statement (PDAS) has been prepared on behalf of Biomethane (Castle Eaton) Limited (hereafter “the applicant”) in support of a full planning application for proposed alterations to the existing Castle Eaton Anaerobic Digestion (AD) Plant, located at Castle Eaton, Swindon SN6 6JX.
1.1.2 The proposed development seeks to upgrade the existing plant and machinery to meet current industry standards and relevant Environment Agency (EA) requirements. The proposal will refine the layout of plant and equipment that forms part of the existing AD facility and also extend the site to the south in order to provide space for new silage clamps, rainwater lagoon, effluent lagoon and relocated feed hoppers. The existing site facility comprises approximately 2.1 hectares (ha) while the adjoining land to the south comprises a 3.7ha arable field.
1.1.3 This PDAS provides a description of the proposed development and sets out the need for the scheme before assessing it in the context of national and local planning policy. It also summarises the environmental assessments and explains how they have helped to inform the evolution of the site layout.
1.2 The Planning Application Submission
1.2.1 This PDAS has been prepared pursuant to the Town and Country Planning Act 1990 (as amended) and the Town and Country Planning (Development Management Procedure) Order 2015 (‘DMPO’) and should be read in conjunction with the following supporting documents:
• Completed application forms including Certificates of Ownership and notices; • Plans and drawings prepared to national and local validation requirements; • Landscape and Visual Appraisal; • Arboricultural Planning Statement; • Preliminary Ecological Appraisal (included as part of the pre-application enquiry); • Hedgerow Survey; • Ecological Impact Assessment; • Biodiversity Assessment (including BNG Calculations); • Archaeological Desk-Based Assessment; • Geo-Environmental and Geotechnical Assessment; • Noise Assessment;
1 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
• Flood Risk Assessment (including Drainage Assessment); • Odour Impact Assessment; • Preliminary Risk Assessment (included as part of the pre-application enquiry); and, • Highway Statement.
1.2.2 The site lies within the administrative area of Swindon Borough Council (SBC) and as such this planning submission has been prepared in accordance with SBC’s validation checklist. It has also taken into consideration comments received through SBC’s pre- application response (planning ref. S/PMIN/20/0991) dated 23rd September 2020 (See Appendix A).
1.3 Structure of this Statement
1.3.1 This PDAS is divided into 6 sections. Following this introduction (Section 1) the structure is as follows:
• Section 2 provides a site description, describing the application site, its setting and planning history; • Section 3 outlines the project description and benefits, providing an overview of the project and related elements including the need for the development and benefits offered by the proposed development; • Section 4 sets out the relevant national and local planning policy context; • Section 5 explains the key planning considerations and demonstrates why planning permissions should be granted; and • Section 6 presents the conclusions of this Statement.
1.3.2 The following figures listed within Table 1 are submitted as part of the planning application.
Table 1 : Figures List
Drawing Reference Title
GGP-28759-PL-101 Existing Site Plan
GGP-28759-PL-102 Proposed Site Plan
GGP-28759-PL-103 Enlarged Proposed Part Site Plan (Sheet 1)
GGP-28759-PL-104 Enlarged Proposed Part Site Plan (Sheet 2)
GGP-28759-PL-105 Enlarged Proposed Part Site Plan (Sheet 3)
GGP-28759-PL-106 Proposed Sections
2 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
GGP-28759-PL-107 Existing and Proposed Elevations
GGP-28759-PL-108 Existing and Proposed Elevations
GGP-28759-PL-109 Existing and Proposed Elevations
GGP-28759-PL-110 Site Location Plan
Elevations-Technic_castle Technical Elevations eaton_MJ_201119
3 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
2 SITE DESCRIPTION
2.1 Site Location
2.1.1 The development site is located on a 5.8-hectare (ha) area of land at Castle Eaton Farm, Swindon SN6 6JX (See Figure GGP-28759-PL-110 Site Location Plan). The upgrade of the existing AD Plant consists of an area of 2.1 ha while the site extension to the south lies on an agricultural field measuring 3.7 ha in area. The site is situated within a predominantly agricultural setting, with the majority of the surrounding area comprising agricultural fields and interspersed woodland plantations, with clusters of residential dwellings and individual farmsteads.
2.1.2 The site is located approximately 350m south west of the village of Castle Eaton and approximately 10km north of Swindon. Immediately north of the site are a variety of industrial units that form part of Poplars Business Park, and approximately 100m south of the site’s southern boundary is a 90ha solar PV array. There are no residential properties within the immediate surrounds of the site. The closest residential properties are located approximately 315m northwest of the northern site boundary, along Water Eaton Lane. Further residential properties are located within the village of Castle Eaton. There is a single residential property located approximately 1km south of the site, which is associated with Droveway Kennels. 2.2 Site Description and Existing Operations
2.2.1 The site comprises an existing AD plant with the area proposed for expansion to the south incorporating an arable field, occupying approximately 2.1ha and 3.7ha respectively. The AD plant has been in operation since 2015 and utilises locally grown maize, rye and grass as feedstock in order to produce biogas which is then used on site to generate electricity for the national grid, heat for adjoining buildings and digestate, a bi-product of the AD process, which is sold back to local farms for use as an organic fertiliser. The existing facility also has planning permission for a gas upgrader which enables a direct gas to grid connection through the export of surplus biogas as biomethane, however this is not currently operational.
2.2.2 The energy produced by the plant is low carbon, sustainable and renewable and is therefore supportive of national objectives to de-carbonise the UK’s energy supply and to incorporate de-centralised, local energy generation capacity.
2.2.3 The existing plant has been the subject of various planning permissions as set out within Table 1, and currently comprises the following elements:
• 3no. anaerobic digesters; • Gas cleaning plant; • Plant room; • Feed and liquor tanks; 4 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
• Silage clamps; • Gas upgrader; • Combined Heat and Power (CHP) Plant; • Digestate lagoon; • Site entrance; and • Hardstanding.
2.2.4 The existing site layout along with the area proposed for expansion can be identified at Figure GGP-28759-PL-101.
2.3 Site Access
2.3.1 The site is accessed via an unidentified road known as Droveway. The A419 (Blunsdon Bypass) lies approximately 3.75km to the south west.
5 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
3 ENVIRONMENTAL BASELINE
3.1 Access and Trip Generation
3.1.1 The site is accessed via an existing private road from a priority junction off Water Eaton Lane. The access operates safely and benefits from a large radius suitable for HGVs turning in and out.
3.1.2 Vehicle movements are based on a 6-day week, 52-weeks a year. Existing daily movements to the site are as follows:
• Feed stock: 10x 13-tonne HGVs a day, equating to around 6,462 two-way movements per annum;
• Digestate collection: 8x 16-tonne HGVs a day, equating to around 4,725 two-way movements per annum;
• Operational: 4 vehicles a day, equating to around 2,496 two-way movements per annum; and
• Maintenance: 1 vehicle a day, equating to around 624 two-way movements per annum.
3.1.3 This equates to approximately 46 vehicles (two-way movements) a day on the network.
3.2 Landscape
3.2.1 The development sits within an existing AD Plant which is situated within an agricultural context. The site extends into an arable field to the south. Several buildings and agricultural units sit amongst 3 digesters tanks and 3 silage clamps. The site’s northern boundary is partially defined by a bund which continues southwards along the western boundary, creating a u-shaped enclosure. The remainder of the northern boundary skirts around existing agri-industrial buildings to join the roadside hedge. A series of hedges and ditches which line the roadside make up the eastern boundary. A second bund is also present, loosely mirroring that of the western boundary. The site is dissected by a mature hedgerow and several oak trees which run from west to east. South of this is a small agricultural field with mature hedgerows making up its eastern and southern boundaries. The western boundary is largely open and shows signs of a historic hedgerow.
3.2.2 The wider study area (2km) straddles countryside within Gloucestershire and Wiltshire counties with irregular shaped, predominantly arable agricultural fields. Some pastoral fields are apparent in the area, supporting grazing for horses and sheep. Blocks of woodland and several woodland belts are also present. Although the site is within the countryside it is close to several settlements, which are connected by a busy highways network. The southern edge of the town of Swindon is 5.5km north-west of the site. The Thames Path follows the river leading into the closest settlement Castle Eaton. 6 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
3.2.3 The site and study area are located within NCA108 Upper Thames Clay Vales National Landscape Character Area, characterised as is a broad belt of open, gently undulating lowland farmland on predominantly Jurassic and Cretaceous clays. The key characteristics of the NCA108 are:
• Woodland cover is low, but hedges, hedgerow trees and field trees are frequent;
• Wet ground conditions and heavy clay soils discourage cultivation in many places, giving rise to livestock farming;
• In the river corridors, grazed pasture dominates, with limited areas of historic wetland habitats including wet woodland, fen, reedbed and flood meadow; and
• Settlement is sparse on flood plains, apart from at river crossings, where there can be large towns, such as Abingdon. Major routes include mainline rail, canals, a network of roads including the M40 and M4 and The Ridgeway and Thames Path National Trails.
3.2.4 The site is located in the very north-west corner of Local Landscape Character Area (LCA) (i) Thames Vale, which is described as ‘alluvial plain adjoining the river Thames. Water plays an important role in forming this landscape, which includes a proliferation of ditches. In conjunction with the existing hedgerows, there are occasional blocks of tree planting, punctuating the landscape. Although development has taken place within this area, it is dominated by a series of small settlements with scattered, isolated groupings making up the remainder.
3.2.5 The site nor the study area fall within an AONB but is within close proximity to the Cotswold AONB and North Wessex Downs AONB.
3.2.6 the local landform, woodland belts and hedgerows result in a site which is visually well contained from the surrounding area. The exception is the area of arable fields directly adjoining to the east and west of the site.
3.3 Ecology
3.3.1 The site comprises the existing AD plant, arable farmland and bare ground, an contains an arable field bordered by hedgerows with earth banks, bare ground as well as hardstanding and buildings making up the AD plant. The site is situated within a largely rural landscape and is surrounded by arable and pasture fields to the immediate north, south, east and west. The River Thames is located c.630m to the north of the site.
3.3.2 No statutory designated sites are located within 1 km of the site. The site is located within the Great Western Community Forest. No other non-statutory designated sites are within 1km of the site. There is an area of ancient woodland c. 156m to the south of the site.
3.3.3 The botanical value of habitats on the site are considered to be limited and only of local value. Two species-poor hedgerows are present on the eastern and southern boundaries of the site. These are poorly structured and contain limited number of species, with English elm (Ulmus procera) and hawthorn (Crataegus monogyna) being the most
7 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
prevalent. A species rich hedgerow is present in the centre of the site. This hedge contained six woody species, hawthorn and blackthorn (Prunus spinosa) but other species frequently found included field maple (Acer campestre), ash (Fraxinus excelsior), dog-rose (Rosa canina) and occasional pedunculate oak (Quercus robur), common lime (Tilia europea) and elder (Sambucus nigra). Three hedgerow features were also present (the hedge was entire, had a ditch and standard trees,) Therefore this is an important hedgerow.
3.3.4 The hedgerows on site provide suitable foraging habitat and some commuting habitat for bats and hedgehogs. There are no suitable roosting features on site. The hedgerows and earth berm provide suitable habitat for badger sett creation but there was no evidence of badger (Meles meles) setts on or within 30m of the site.
3.3.5 The hedgerows and scattered trees provide suitable habitat for nesting birds. House sparrows (Passer domesticus) and common chaffinch (Fringilla coelebs) were recorded on the hedgerows and pied wagtails (Motacilla alba) were recorded using the buildings on site. Great Crested Newts (GCN) are considered to be likely absent from the site. Whilst there is a small area of suitable basking habitat for reptiles provided by the earth berm and tall ruderal vegetation, reptiles are likely absent from the site due to lack of connectivity.
3.4 Arboriculture
3.4.1 There are no Tree Preservation Order (TPO) protected trees on the site and the site is not situated within a Conservation Area. Tree cover was mainly confined to the boundaries of the site, with a few small groups of trees around the site buildings. There is a limited range of tree species across the site and most trees are situated within the hedgerows around the boundaries of the site. These are comprised of young Hawthorn and Ash.
3.4.2 The majority of the trees are categorised as low-quality Grade C. This is partly due to the presence of a high number of Ash trees which are infected with Ash Dieback (Hymenoscyphus fraxinea), and therefore in decline.
3.5 Cultural Heritage
3.5.1 There are no designated assets located within the site boundary.
3.5.2 There are 15 designated assets located within the study area, including post-medieval period Grade II listed buildings which represent the settlement centre at Castle Eaton. The Castle Eaton Conservation Area is located approximately 35m northeast of the northernmost extent of the site.
3.5.3 There are no scheduled monuments, registered battlefields, registered parks and gardens or World Heritage Sites within the site or study area.
3.5.4 There is a single non-designated asset located within the site boundary: areas of medieval ridge and furrow at Castle Eaton.
8 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
3.6 Ground Conditions
3.6.1 A Preliminary Risk Assessment (PRA) for the site was undertaken in August 2019 by Argyll Environmental (report ref.: AEL-0016-LSC-976203) which identified that no significant contaminant linkage has been identified and accordingly soil and groundwater liabilities are unlikely to occur.
3.6.2 A review of historical mapping of the site dating from 1875 shows that the site remained undeveloped until c.1974 when land to the northeast of the site formed part of a wider agricultural holding, which then. formed part of a yard associated with light industrial land uses after c.1994. No further changes were identified from until sometime between 2006 and 2019 when the AD plant was developed.
3.6.3 Regulated processes on site include revoked Discharge Consent for farms and a Licensed Waste Management Facility for anaerobic digestion using farm wastes only that appears to relate to on Site operations. The site is currently used as an AD plant. As a result of historical and current use of the site there is a moderate risk of contaminants being present.
3.6.4 Potentially contaminative uses within 100m of the site are limited to the light industrial uses to the north from 1994-present. There is therefore a low to moderate risk of contamination affecting the site.
3.6.5 The site and study area are within light industrial and agricultural land uses, with no residential properties located within 100m. The superficial hydrogeology underlying the site is classified as a Secondary (A) Aquifer (deposits with moderate permeability) and the bedrock hydrogeology is classified as an Unproductive Stratum (deposits of negligible permeability).
3.6.6 The site is not situated within a groundwater Source Protection Zone (SPZ) and there are no water abstraction licenses located within 500m however there is a drain located 169m west of the site. There are no designated eco-receptors within a 500m radius.
3.7 Flood Risk and Drainage
3.7.1 The site is comprised of the existing AD facility and agricultural land, containing areas of hardstanding on the site with the inclusion of an access track. The site is approximately 29% impermeable surface and 71% permeable.
3.7.2 From available LiDAR data (1m DTM 2019) the site is relatively flat with levels generally ranging from 81mAOD to 78mAOD. Due to the nature of the existing development, there are areas of raised ground in the northern section of the site above these levels associated with the stockpiles and the existing bunding. The southern site shows a gentle fall from west to east from approximately 80.5mAOD on the western boundary to 78.9mAOD adjacent to the access track.
3.7.3 Available OS mapping highlights an Ordinary watercourse originating approximately 220m to west of the development. The watercourse flows in a westerly / northerly
9 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
direction towards the River Thames.
3.7.4 The River Thames / Isis (Main River) is located approximately 500m to the north of the site at its closest point, with the main channel approximately 620m to the north of the site.
3.7.5 The site exhibits Summertown-Radley Sand and Gravel Member - Sand and Gravel superficial geology and Oxford Clay Formation – Mudstone bedrock geology.
3.7.6 The site is underlain by both a ‘Secondary undifferentiated’ bedrock aquifer and a ‘Secondary A’ superficial aquifer.
3.7.7 The site is not located within a Groundwater Source Protection Zone (SPZ). The closest Groundwater SPZ is a ‘Zone II – Outer Protection Zone located approximately 850m north of the site.
3.8 Noise
3.8.1 The dominant noise sources during the baseline survey consisted of traffic on the local road network and farm noise. Noise from a limited number of light goods vehicle movements accessing/ leaving the AD plant and the adjacent employment units (i.e. Poplar Business Park) was audible from the nearest locations from the site during the installation and retrieval of the sound level meters.
3.8.2 The Castle Eaton AD Plant is currently not operational, therefore noise attributed to the consented AD plant would not have formed part of the background noise levels identified during the survey. The only noticeable noise sources associated with the operation of the plant were some movements of light goods vehicles accessing/ leaving the AD plant and the adjacent employment units.
3.8.3 The main noise source affecting the nearest sensitive receptors to the site is noted to be road traffic at the main road accessing Castle Eaton (Water Eaton Lane/School Lane), as well as noise generated from agricultural machinery on agricultural fields in the area.
3.9 Odour
3.9.1 As previously stated, the application proposals seek to upgrade and extend the existing AD facility in order to make more efficient use of the energy crop feedstocks and available area by enabling increased retention times for substrates in the digestion process and therefore generating an increased gas yield. Longer substrate residence times in the digestion process will result in increased biological stability in the digestate, and therefore lower odour emissions potential in the digestate.
3.9.2 The existing baseline scenario at the proposed site has been identified as follows:
• For the existing/baseline scenario, the 5-year average annual 98th percentile hourly mean odour concentrations are below the suggested odour benchmark of 3 5.0 European Odour Units per cubic metre (ouE/m ) at all modelled receptors, except for commercial receptors R10 and R11 which are located adjacent to the 3 AD plant. The highest modelled odour impact is 8.67 ouE/m at R10. 10 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
• The modelled odour impacts are well below the EA H4 exposure benchmark of 3 3.0 ouE/m at all residential receptors (i.e. R1-R8), and predicted impacts are also 3 all below the more stringent 1.5 ouE/m standard.
3.10 Public Rights of Way
3.10.1 There are no Public Rights of Way (PRoW) that pass through the site. The Thames Path follows the River Thames and passes approximately 500m north of the site boundary at its closest point. Due to local topography and mature existing vegetation, potential visibility from PRoW would be limited to those in the immediate vicinity of the site and areas of higher topography such as Lushill, south-east of the site. Views from PRoW are often confined by woodland belts and vegetation within close proximity to the PRoW and the proposed development would not actually be visible from all the PRoW within the ZTV.
3.11 Planning History
3.11.1 The planning history of the site is summarised in Table 2 below:
Table 2 : Planning History
Application No. Status Project Description
S/12/0317 Approved Construction of 2no. The development of an anaerobic digesters, Anaerobic Digestion (23 Jul 2012) plant room, feed and Plant, which processes liquor tanks, silage purpose grown energy clamps, digestate crops via digestion lagoon, amended technologies into biogas entrance and and agricultural fertilisers. hardstanding on Land at Castle Eaton Farm Castle Eaton Wiltshire SN6 6J.
S/COND/12/1476 Approved Discharge of Discharge of conditions 2, conditions from 3, 4, 5, 7, 9, 10 and 21 (15 Nov 2012) Planning Permission relating to application ref. S/12/0317. S/12/0317.
S/12/1515 Approved Variation of approved Regularisation of ‘as built’ plans, under condition (21 Jan 2013) elements of the Caste 11 of previous Eaton AD Plant. permission S/12/0317, for minor revisions to include replacement of feed 11 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
hopper with a low sealed tank (2.3m high) and re-siting of technical building and associated plant.
S/AGRI/13/1081 Approved Prior Approval The installation of a Notification for the digestate storage lagoon (2 Sept 2013) installation of a on land south of the bunded liquid approved AD Plant to slurry/fertiliser lagoon facilitate the plant for the storage of processes. digestate on Land at Castle Eaton Farm Castle Eaton Wiltshire SN6 6J.
S/14/1308 Approved Erection of an The installation of a third anaerobic digester digestor to increase the (17 Nov 2014) and a grain storage capacity of the existing building on Land at Castle Eaton AD Plant. Castle Eaton Farm Castle Eaton Wiltshire SN6 6J.
S/14/1309 Approved Installation of an The installation and anaerobic digestor operation of a gas (17 Nov 2014) gas conditioning and conditioning and compression plant on compression plant to Land at Castle Eaton facilitate export of Farm Castle Eaton biomethane into the Wiltshire SN6 6J. National Transmission System.
S/17/0717 Approved Retention of earth Regularisation of bund and 2m. high landscaped earth bund (11 Jul 2017) security fencing on and security fencing Land at Castle Eaton already installed at the Farm Castle Eaton Castle Eaton AD Plant. Wiltshire SN6 6J.
S/17/0718 Approved Erection of carbon Installation of machinery capture plant and for the purpose of (11 Aug 2017) tanker filling point, capturing, storing and re- retention of site office using carbon dioxide and relocation of byproducts of the AD approved gas processes. Machinery 12 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
conditioning plant on includes cleaning and Land at Castle Eaton liquification equipment, Farm Castle Eaton 2no. storage cylinders Wiltshire SN6 6J. and loading bay.
13 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
4 THE PROPOSED DEVELOPMENT
4.1 Overview
4.1.1 The proposed development seeks to upgrade the existing plant and machinery to meet current industry standards and relevant Environment Agency (EA) permitting requirements. Furthermore, these improvements would make more efficient use of the available area, allowing for increased retention time of substrate in the digestion process and therefore increased gas yield, and enable future gas to grid connectivity. See Figure GGP-28759-PL-102 for detail of the proposed site layout, Figure ref. Elevations- Technic_castle eaton_MJ_201119 for the proposed equipment elevations and Figures GGP-28759-PL-107 to GGP-28759-PL-109 for existing and proposed site sections.
4.1.2 In order to achieve the above aims, the proposed development seeks to introduce the following elements to the operation:
• Erection of 1no. additional digestor; • Removal of existing silage clamps and installation of replacement clamps; • Construction of an effluent lagoon for run off from the new silage clamps; • Construction of a rainwater lagoon; • Establishment of a new separation area and digestor offtake; • Upgrading and relocating 2no. existing feed hoppers; • Construction of a welfare/office building; • Erection of a flare stack; • Construction of a weighbridge; and • Construction of a replacement gas upgrader unit/ network entry facility/ Carbon Dioxide (CO2) sequestration area.
4.1.3 The gas upgrade plant will allow for the plant to export biomethane into the gas transmission system, thereby displacing natural gas. Fuel substitution in this way supports the de-carbonisation of the hard-to-reach sector of domestic cooking and heating, therefore supporting the UK’s legally binding target of achieving net zero by 2050.
4.1.4 Export to grid is also cleaner than the alternative of burning gas to generate electricity. 4.2 Layout
4.2.1 The site layout has been designed to optimise the operational use of the site and ensure that the bulkiest structures are located adjacent to the existing tanks in a location where they are visible alongside buildings associated with Poplar Business Park. The ancillary structures such as the silage clamps are sited to the south of the tanks away from sensitive receptors.
14 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
4.3 Scale
4.3.1 The development will consist of the elements outlined in section 4.1.2 above, with the purpose of upgrading and extending the existing AD Plant. The total area of the site will comprise 5.8ha. Whilst the overall scale of the development would increase, the scale of the proposed development will be reflective of the existing facility and in keeping with the local landscape pattern and scale.
4.3.2 The proposed site infrastructures are generally of a smaller scale and integrate into the existing plant infrastructure. Proposed elements of more significant scale include the flare stack, additional fermenter tank and office and welfare units.
4.3.3 Dimensions for the proposed technical elements on site are summarised in Table 3 below:
Table 3: Technical Dimensions
Proposed Element Dimensions (metres) (height x width x depth)
Biogas Upgrading Unit 3.5 x 19.95 x 12.5
CO2 Recovering Unit 3.5 x 16.0 x 10.0
CO2 Tanks 3.12 x 16.9 x 13.2
Office and Welfare Units 6.02 x 8.0 x 3.0
Network Entry Facility 2.66 x 9.75 x 3.25
Gas Flare (Upgrading) 10.6 x 6.2 x 4.0
Gas Flare (CHP) 6.34 x 5.05 x 3.0
Propane Tanks 1.96 x 15.5 x 5.39
Separation Unit 5.17 x 4.7 x 1.9
Feed Hoppers 5.4 x 14.36 x 3.82
Fermenter Tank 18.23 x 30.64 x 30.64
Gas Cooling System 4.8 x 5.48 x 1.6
4.3.4 Mitigation measures incorporated into the project design for the proposed development
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include:
• Retention of the 2m high existing earth bunding;
• Erection of a 2.5m timber acoustic fence around the proposed gas upgrader unit;
• Proposed native mixed scrub and tree plantings along north-western and western boundaries;
• Proposed native mixed wildflowers in eastern portion of the site around the proposed site offices and welfare cabins;
• Retention of important hedgerow dissecting the site; and,
• Proposed hedgerow planting on western and southern boundaries. 4.4 Design
4.4.1 The appearance of the proposed development is driven primarily by its operational need but the choice of material and colour is designed to minimise visual impact and integrate with the existing facility.
4.4.2 The most prominent feature will be the additional fermenter tank, which will comprise profiled steel insulated sheeting and a plastic gas tight membrane to match the existing. The buildings will comprise profiled steel sheeting to match those existing.
4.4.3 The proposed timber acoustic fencing will be stained green to aid in visual screening of the plant and machinery from north-western viewpoints looking south and southeast. 4.5 Use
4.5.1 AD produces renewable energy by breaking down organic materials to release biogas. An anaerobic digestor is essentially a large mechanical digestive system which requires regular feeding, and the feedstock materials are digested using a variety of chemical and biological processes.
4.5.2 Agricultural feedstock in the form of maize, rye and grass is transported to site by 13- tonne HGVs and stored in silage clamps. The ensiled materials are covered with impermeable sheet covers, stacked in layers, and compacted. The feedstock material remains in the clamps until required to feed the digesters. Silage is then extracted from the working faces and transferred directly to a feed hopper.
4.5.3 The digestion process then operates in a closed system, where the oxygen is removed to create an anaerobic environment. Like in an animal, the digestion processes in AD work best when conditions are stable, for example by maintaining a consistent temperature to allow the microorganisms and enzymes involved in the process to function optimally. The digestion process takes place in four stages.
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• Hydrolysis - In the first step of digestion, the long and complex molecules in biological waste materials are split into simple parts, such as sugars, fatty acids and amino acids. • Acidogenesis - In acidogenesis, the simple molecules are further broken down in a fermentation process, carried out by available bacteria. Volatile fatty acids, ammonia, carbon dioxide and hydrogen sulphide are formed during this stage. • Acetogenesis - The products from the acetogenesis process are further digested to produce acetic acid, plus some carbon dioxide and hydrogen. • Methanogenesis - Specialist bacteria called methanogens use the products from the previous steps to generate methane, carbon dioxide and water. The biogas released is mostly made up of this mix of products, plus some impurities.
4.5.4 The biogas mixture alone has limited use for providing renewable energy. There are two main options available to make use of biogas – upgrading it to methane or using in a Combined Heat and Power (CHP) system.
4.5.5 The biogas mixture can be upgraded to biomethane, the renewable equivalent of natural gas, using a biogas purification and upgrading system. This removes less desirable products such as carbon dioxide and volatile organic compounds, leaving pure biomethane, which can then be injected into the national grid to be used in home boilers in exactly the same way as its fossil fuel equivalent.
4.5.6 In CHP systems, the biogas produced in the anaerobic digestion process is burnt in a controlled manner, releasing thermal energy, which heats water to steam which powers a generator. The electricity from the generator can then be injected into the grid. The heat released during the CHP process can also be used by the AD facility and to heat other buildings in the local area.
4.5.7 Biogas is not the only product which comes from the anaerobic digestion process. There is also digestate, which is the left over solid and liquid materials once the biogas has been released and siphoned off. Digestate is sometimes referred to as a by-product, however it is a useful substance in its own right, as it can be spread on agricultural land to provide a nutrient rich organic fertiliser. After digestion, a solids separator will be used to remove the solid fibrous fraction from the liquid digestate. Digestate solids, which are predominantly fibrous in nature, will be stored temporarily within one of the clamps prior to being taken away for spreading on land as organic compost. The liquid component of the digestate will be stored in an existing digestate lagoon to the south of the site, approximately 1.2km away.
4.6 Need for the Proposal
Sustainable Energy Production
4.6.1 Our Waste, Our Resources: A Strategy for England (Defra, 2018)1 states that natural capital is one of our most valuable assets and sets out how the Government will preserve
1 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/765914/resources-waste- strategy-dec-2018.pdf 17 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
our stock of material resources by minimising waste, promoting resource efficiency and moving towards a circular economy. According to the strategy, AD represents the best environmental outcome for waste streams, including agricultural, that cannot be prevented or used as animal feed. It provides both low carbon renewable energy and digestate, which can be used as fertiliser, compost, or soil improver.
4.6.2 Since the publication of the Anaerobic Digestion Strategy and Action Plan in 20112, AD growth has been supported by measures such as feed-in tariffs (closed to new applications April 2019) and renewable heat incentives. The number of AD facilities using food waste or farm waste in operation since then has increased from 63 to 420 and energy recovered from AD has increased from 713 GWh in 2013 to 2,470 GWh in 2017. AD also produced 3,500 GWh of heat in 2017.
4.6.3 According to the National Non-Food Crops Centre (NNFCC) there are now 579 operational AD plants in the UK, and a further 331 AD projects under development 3. In the 2020 Spring Budget, the Chancellor announced a £10 million allocation for net-zero policies and programmes, which includes a Green Gas Support Scheme (GGSS) for biomethane from AD only, funded by a green gas levy.
4.6.4 AD growth has also increased the amount of digestate available to be spread to land to improve soil or as a fertiliser. This helps to reduce dependency on inorganic chemical fertilisers and their higher carbon footprint.
Achieving Net Zero
4.6.5 Climate change is well researched and documented. It is widely accepted that there is a need for a huge reduction in worldwide greenhouse gas emissions. In the UK this will be achieved through both the conservation of energy by moving to low energy appliances and better insulated buildings, and through the production of all forms of renewable and low carbon energy.
4.6.6 On 27 June 2019 the UK became the first major economy in the world to pass laws to end its contribution to global warming by 2050. The target will require the UK to bring all greenhouse gas emissions to net zero by 2050, compared with the previous target of at least 80% reduction from 1990 levels. The UK has already reduced emissions by 42% while growing the economy by 72% and has put clean growth at the heart of our modern Industrial Strategy. This could see the number of “green collar jobs” grow to 2 million and the value of exports from the low carbon economy grow to £170 billion a year by 2030.
4.6.7 The UK’s 2050 net zero target — one of the most ambitious in the world — was recommended by the Committee on Climate Change, the UK’s independent climate advisory body. Net zero means any emissions would be balanced by schemes to offset an equivalent amount of greenhouse gases from the atmosphere, such as planting trees or using technology like carbon capture and storage
2 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/69400/anaerobic-digestion- strat-action-plan.pdf 3 https://www.nnfcc.co.uk/news-ad-a-challenging-year 18 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
4.6.8 Overarching National Policy Statement for Energy (EN-1) outlines the Government’s desire to source 15% of the Countries total energy requirement from renewable energy by 2020. The Statement identifies throughout that there is a need for a strategic network of various types of renewable energy development to meet this target.
4.6.9 The proposed development is inclusive of plant and machinery upgrades to an operational AD plant which generates renewable energy. The proposed development seeks to increase the retention time of the biogas, removing the requirement to burn excess gas on site thereby decreasing the overall carbon footprint of the AD process. Furthermore, the proposed plant and machinery upgrades will enable the plant to be connected to the National Transmission System (NTS) in the future, allowing for direct export of biomethane into the grid.
4.6.10 Through improvement of the existing operations on site, it is understood that the proposal will reduce the greenhouse gas emissions of the operational plant, therefore the facility will be low carbon with the view of achieving net zero.
4.6.11 Due to the production technique for biomethane, AD is regarded as a renewable form of low carbon energy. The benefits brought by the applicant assist the UK in meeting its low emission targets and preparation for the eventual shift to a carbon neutral based economy by 2050. 4.7 Project Benefits
4.7.1 In summary the proposed development is anticipated to provide the following main benefits:
• Improved retention time of substrate in the digestion process with associated improved control of digestate quality and related issues such as odour; • Improve site infrastructure to meet current environmental standards; • Improved economic efficiency from the plant; and, • Allowing the plant to be better equipped for gas export to the gas transmission system displacing natural gas use.
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5 PLANNING POLICY CONTEXT
5.1 Energy White Paper
5.1.1 On 14 December 2020, the UK government published an Energy White Paper (Powering our net zero future) setting out how the UK will clean up its energy system and reach net zero emissions by 2050.
5.1.2 The white paper seeks to place net zero and the government’s effort to fight climate change at its core. It follows the Prime Minister’s Ten Point Plan for a Green Industrial Revolution which sets out how government investment will leverage private investment and support up to 250,000 jobs by 2030. The success of this will rest on a decisive shift away from fossil fuels to using clean energy for heat and industrial processes, as much as for electricity generation.
5.1.3 Biomethane is currently the only green gas commercially produced in the UK. It can be injected into the gas grid to accelerate the decarbonisation of gas supplies. The white paper categorically states that the government will increase the proportion of biomethane in the gas grid. Furthermore, the 2020 Budget announced that a green gas levy imposed on gas suppliers will fund a new support scheme to achieve this goal, the first of its kind applied to gas in Britain.
5.1.4 Subject to the outcome of a consultation which the government intend to publish a response to in early 2021, the GGSS is expected to launch in autumn 2021 and run for four years. It will support continued deployment of anaerobic digestion biomethane plants in order to increase the proportion of green gas in the grid. It is anticipated that the GGSS could deliver annual generation of 2.8TWh of renewable heat in 2030/314, the equivalent of the gas requirements roughly 230,000 homes5. This scheme will be designed to minimise any associated negative environmental impacts from the anaerobic digestion process, such as ammonia emissions. These new measures have the potential to treble the amount of biomethane in the grid between 2018 and 2030. 5.2 Online Planning Practice Guidance: Renewable and low carbon energy
5.2.1 The online PPG (June 2015)6 provides advice on the planning issues associated with the development of renewable energy and confirms that increasing the amount of energy from renewable and low carbon technologies will help to ensure the UK has a secure energy supply, reducing greenhouse gas emissions to slow down climate change and stimulating Investment in new jobs and businesses.
4 BEIS (2020), ‘Consultation Stage IA: Future Support for Low Carbon Heat’ 5 Ofgem, ‘Typical Domestic Consumption Values’, accessed 21/10/2020 6 MHCLG, Renewable and low carbon guidance, https://www.gov.uk/guidance/renewable-and-low-carbon-energy 20 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
5.2.2 The guidance reiterates that the NPPF requires all communities to have a responsibility to help increase the use and supply of green energy. However, this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities. As with other types of development, it is important that the planning concerns of local communities are properly heard in matters that directly affect them. The guidance states that community concerns should be addressed through local and neighbourhood plans, whilst also giving advice concerning how to identify suitable areas, criteria-based policies and buffer zones/separation distances. (Paragraph: 003 Reference ID: 5-003-20140306, Revision date: 06.03.2014) 5.3 National Planning Policy Framework
5.3.1 The revised National Planning Policy Framework (NPPF)7 was published in February 2019. It sets out the Governments planning policies for England and how these should be applied. The NPPF provides the national policy context against which planning decisions should be considered and is a material consideration when determining planning applications.
5.3.2 Paragraph 7 states that the purpose of the planning system is to contribute to the achievement of sustainable development. It has three overarching objectives (economic, social and environmental) which are interdependent and need to be pursued in mutually supportive ways.
5.3.3 Central to the NPPF is 'a presumption in favour of sustainable development'. This is highlighted in Section 4: Decision Making (RSK emphasis added in bold). ‘…Decision- makers at every level should seek to approve applications for sustainable development where possible.’
5.3.4 Paragraph 83 supports a prosperous rural economy and states that ‘…decisions should enable:
a) the sustainable growth and expansion of all types of business in rural areas, both through conversion of existing buildings and well-designed new buildings; b) the development and diversification of agricultural and other land-based rural businesses;’
5.3.5 Section 14 9Meeting the challenge of climate change, flooding and costal change) sets out a number of core planning principles that should underpin decision making.
5.3.6 Paragraph 148 states that:
‘The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage reuse of existing resources,
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including conversion of existing buildings and support renewable and low carbon energy and associated infrastructure.’
5.3.7 Paragraph 151 states that:
‘To help increase the use and supply of renewable and low carbon energy and heat, plans should:
a) Provide a positive strategy for energy from these sources, that maximises the potential for suitable development, whilst ensuring that adverse impacts are addressed satisfactorily (including cumulative landscape and visual impacts); b) Consider identifying suitable areas for renewable and low carbon energy sources and supporting infrastructure, where this would help to secure their development; and c) Identify opportunities for development to draw on its energy supply from decentralised, renewable or low carbon energy supply systems and for co- locating potential heat customers and suppliers.’
5.3.8 Paragraph 154 states that:
‘When determining planning applications for renewable and low carbon development, local panning authorities should:
a) Not require applicants to demonstrate the overall need for renewable or low carbon energy, and recognise that even small-scale projects provide a valuable contribution to cutting greenhouse gas emissions; and b) Approve the application if its impact are (or can be made) acceptable. Once suitable areas for renewable and low carbon energy have been identified in plan, local planning authorities should expect subsequent applications for commercial scale projects outside these areas to demonstrate that the proposed location meets the criteria used in identifying suitable areas.’
5.3.9 The proposed development is consistent with these NPPF policies as it will reduce greenhouse emissions from the anaerobic digestion process with no carbon dioxide emissions being produced. The energy produced from this process is low carbon, sustainable and renewable.
5.3.10 Section 6 (Building a strong, competitive economy) highlights the importance of supporting a prosperous rural economy.
5.3.11 Paragraph 83 states that:
‘Planning policies and decisions should enable:
a) the sustainable growth and expansion of all types of business in rural areas, both through conversion of existing buildings and well-designed new buildings; b) the development and diversification of agricultural and other land-based rural businesses …’
5.3.12 The proposed development aligns with this section of the NPPF as it will enable the expansion and diversification of an agricultural business withing a rural area.
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5.3.13 NPPF paragraph 148 requires that the planning system supports the transition to a low carbon future through helping to reduce greenhouse gas emissions and encouraging the reuse of existing resources.
5.4 Local Planning Policy
5.4.1 The application falls within the administrative area of SBC who are the determining authority. The following provides an overview summary list of the policies within the statutory development plan that are of relevance to the proposed development:
Adopted Swindon Borough Local Plan (SBLP) 2026 • Policy SD1: Sustainable Development Principles • Policy SD2: The Sustainable Development Strategy • Policy SD3: Managing Development • Policy DE1: High Quality Design • Policy DE2: Sustainable Construction • Policy EC1: Economic Growth through Existing Business and Inward Investment • Policy EC5: Farm Diversification • Policy TR2: Transport and Development • Policy IN4: Low Carbon and Renewable Energy • Policy EN1: Green Infrastructure Network • Policy EN2: Community Forest • Policy EN4: Biodiversity and Geodiversity • Policy EN5: Landscape Character and Historical Landscape • Policy EN6: Flood Risk • Policy EN7: Pollution • Policy EN8: Unstable Land • Policy EN9: Contaminated Land • Policy EN10: Historic Environment & Heritage Assets
Adopted Supplementary Planning Guidance
5.4.2 Supplementary Planning Documents (SPDs) add further detail to the policies in the Local Plan and provide further guidance for development on specific sites, or on particular issues, such as design. Although SPDs and SPGs are not part of the development plan, in 2015, they were assessed as being relevant to policies in the Swindon Borough Local Plan 2026 and consistent with national policy and were approved to continue as a material consideration in planning decisions. Table 3 provides a summary of the relevant documents.
Table 3 : Adopted Supplementary Planning Guidance
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Supplementary Planning Guidance Detail
Inclusive Design Access for All SPD Amplifies Policy DE1 of the adopted Swindon Borough Local Plan 2026 by providing guidance to assist in achieving high quality and inclusive design for all development; including individual buildings, public and private spaces.
Archaeology SPG Provides guidance to developers, architects, agents and landowners where their development proposals impact on archaeological remains
Landscape character areas SPG Provides guidance on the characteristics of each of the Borough's Landscape Character
Areas that should be addressed when considering development proposals within them.
Tree protection on development sites Provides guidance in respect of the SPG preservation of appropriate trees within development schemes.
Nature conservation guidance note Helps developers to determine whether their scheme is likely to affect biodiversity. It sets out what they must do so their planning application is not refused on nature conservation grounds.
Community Forest SPG Seeks to ensure that, where applicable, the aims and objectives of the Community Forest are incorporated into development proposals.
Emerging Swindon Borough Local Plan 2036
5.4.3 SBC are carrying out a review of the current Local Plan for the Borough of Swindon for the period to 2036. The Regulation 19 Proposed Submission Draft Version of the Local Plan was published for public representations and underwent consultation between December 2019 and January 2020. The following shows the replacements for the policies of the Swindon Borough local Plan:
Swindon Borough Local Plan 2026 Policy Emerging Policy
Policy SD1 – Sustainable Development Principles Policy SP1
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Swindon Borough Local Plan 2026 Policy Emerging Policy
Policy SD2 – The Sustainable Development Strategy Policy SP2
Policy SD3 – Managing Development Part in Policy SP2
Policy DE1 – High Quality Design Policy DM1, DM2, DM3
Policy DE 2 – Sustainable Construction Part in Policy DM1
Policy EN1 – Green Infrastructure Network Policy DM28
Policy EN2 – Community Forest Policy DM29
Policy EN4 – Biodiversity and Geodiversity Policy DM32
Policy EN5 – Landscape Character and Historical Landscape Policy DM33
Policy EN6 – Flood Risk Policy DM36
Policy EN7 – Pollution Policy DM37
Policy EN8 – Unstable Land Policy DM37
Policy EN9 – Contaminated Land Policy DM37
Policy EN10 – Historic Environment and Heritage Assets Policy DM34
Policy EC1 – Economic Growth through Existing Business Not carried forward. and Inward Investment
Policy EC5 – Farm Diversification SD2 - The Sustainable Policy DM38 Development Strategy
Policy TR2 – Transport and Development Policy DM21
Policy IN4 – Low Carbon and Renewable Energy Policy DM25
5.4.4 The next steps would be for SBC to review feedback and the document will later be submitted to the Secretary of State for independent examination.
5.4.5 For the purpose of determining this application it is considered that the emerging policy is broadly in accordance with the adopted plan and as such it is considered that greater weight is placed on the adopted policy.
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6 ENVIRONMENTAL CONSIDERATIONS
6.1 Introduction
6.1.1 Pre-application discussions with SBC and reference to the local validation lists indicated that a number of environmental surveys were required to support the application. These have been provided as standalone reports with the planning application submission.
6.1.2 For purposes of conciseness, these reports are not duplicated in full here, but a summary of the key findings is presented as follows.
6.2 Transport and Access
6.2.1 The existing access to the site will be retained and the volume of traffic associated with the existing development will remain unchanged with the proposals.
6.3 Landscape and Visual
6.3.1 The landscape of the study area is predominantly agricultural land which abuts the River Thames with small settlements. The agricultural land is mostly arable, with some pastoral land used for grazing horses and sheep, and pockets of woodland. Perceptibility of the site is limited to its immediate vicinity.
6.3.2 The proposed development would not result in prominent changes to the characteristics of the wider landscape or affect the integrity of landscape designations within the study area due to its unchanged agricultural use.
6.3.3 Where perceptible, the proposed development would be screened by a combination of local landform and the network of mature hedgerows and trees which makes up the local landscape. The proposed equipment height, and double-storey office units, are similar to those on the existing site and will not be prominent to visual receptors.
6.3.4 Opportunities for worthwhile mitigation measures for the proposed development are limited outside the design approach detailed in Section 6.1 of the Landscape and Visual Appraisal submitted as part of this planning application.
6.3.5 In summary, no landscape effects were assessed as being moderate adverse (or greater). No visual effects were assessed as being greater than minor adverse.
6.4 Ecology
Preliminary Ecological Appraisal
6.4.1 An extended Phase 1 Habitat Survey was carried out on 1 November 2019 by Josephine McCarthy (Natural England Bat License Number: 2019-41480-CLS-CLS) of Arbtech Consulting Limited (Arbtech, 2019). The methodology for the was undertaken in accordance with the standard Phase 1 survey methodology (Joint Nature Conservation 26 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
Committee, 2010). This involved the identification and mapping of dominant habitat types to create a habitat map using a set of standard colour codes to indicate habitat types. In addition, although no attempt was made to compile an exhaustive species list, dominant plant species were noted along with any uncommon species, or species indicative of particular habitat types.
Hedgerow Survey
6.4.2 A recommendation of the PEA was to undertake a survey of the hedgerow bordering the south of the existing AD facility on the basis that the hedgerow would be removed. As the hedgerow has six woody species per 30m and over three associated features it qualifies as ‘important’ under the ecological criteria of the Hedgerows Regulations 1997.
6.4.3 Upon confirmation of the survey results it was determined that the hedgerow should be retained. Therefore, the design of the proposed development was subsequently altered in order to retain the important hedgerow. The proposed development is additionally inclusive of further plantings including additional hedgerows associated with biodiversity net gain, which will improve habitat connectivity.
Ecological Impact Assessment
6.4.4 No significant effects are anticipated on any designated site (statutory or non-statutory), hedgerow habitats, or the following legally protected species (badgers, great crested newts and hedgehogs).
6.4.5 Without mitigation significant effects at the local level are anticipated on bats, breeding birds and reptiles.
6.4.6 Mitigation measures outlined within the EcIA include appropriate site clearance methods during suitable times of years, establishment of exclusion zones to safeguard protected species and/or habitats and a sensitive lighting strategy for bats. These measures will ensure that there will be no residual effects on bats, breeding birds or reptiles following the completion of the development.
6.4.7 Enhancements across the site include new and supplementary hedgerow planting, as well as the planting of new trees and shrub. Peripheral habitat around the edge of the AD plant will be seeded and managed as wildflower meadows and a reptile hibernaculum will be created on site.
Biodiversity Assessment
6.4.8 A Biodiversity assessment was carried out as a desk-based exercise using the results of surveys by Arbtech on 1 November 2019 to establish the baseline (pre-construction) ecology of the site and post-construction habitats identified using the Proposed Site Layout Plan provided as part of the Landscape and Ecological Management Plan.
6.4.9 The assessment calculates ‘biodiversity units’ using the Defra biodiversity metric 2.0 and following the methods set out in Defra’s biodiversity metric 2.0 user guide. The calculations are based on the area (or length), distinctiveness, condition, strategic
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significance and connectivity of habitats found on the site.
6.4.10 The assessment concludes that the proposed development will result in a change of +0.42 biodiversity area units (+3.29%) and +2.72 terrestrial linear biodiversity units (+59.65%).
The creation of c.450m of species rich hedgerow cannot be directly compared to arable habitat loss in terms of biodiversity units as it is a linear feature. However, creation of new hedgerows provides valuable wildlife habitat and connectivity in an intensively managed agricultural landscape which outweighs the ecological value, in terms of habitat quality, of 2.55ha of arable land. The creation of the new hedgerows, scrub and grassland habitats, with appropriate management, should compensate for the loss of arable land in terms of habitat quality. In addition, it will provide an area of biodiverse habitat in an intensive arable landscape.
6.5 Arboriculture
6.5.1 An Arboricultural Impact Assessment (AIA) was prepared for the proposed development in line with the requirements of ‘BS5837:2012 Trees in Relation to Design, Demolition and Construction: Recommendations’ (BS5837:2012).
6.5.2 The tree survey undertaken to inform the AIA identified a total of 15 individual trees, seven groups of trees and eight hedgerows, which have the potential to be impacted by the development proposals. In line with the recommendations contained within Table 1 of BS5837:2012, of these tree features, six were awarded a moderate B grade and 24 were awarded a low C grade. None were awarded a high A grade or a very low U grade.
6.5.3 Of the 30 tree features on site at the time of the survey, no tree features will need to be removed to facilitate the proposed development.
6.5.4 In order to ensure the successful integration of retained trees into the proposed development, various tree protection measures will be incorporated into the design which are intended to maintain the trees in a safe and healthy condition including Construction Exclusion Zones and tree protection barriers.
6.6 Cultural Heritage
6.6.1 The study area comprises a 500m buffer surrounding the proposed development site boundary, within which the archaeological and historical development of the site and surrounding area has been considered. Data was gathered for a 1km buffer to inform the baseline and provide a comprehensive overview of the local area.
6.6.2 Historic Environment Record (HER) data and Historic England designation data was collected for the study area alongside historic mapping and LiDAR data.
6.6.3 There are no designated assets located within the site boundary and a total of 15 designated assets located within the study area. These comprise post-medieval period Grade II listed buildings which represent the settlement centre at Castle Eaton. The
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Castle Eaton Conservation Area is located approximately 35m to the north east of the northernmost extent of the site. There is a single non-designated asset located within the site boundary: areas of ridge and furrow at Castle Eaton. There are a further 14 non- designated assets located within the study area.
6.6.4 No important heritage assets are identified within the site boundary and as such no specific direct impacts have been identified as likely to arise from the proposed development of sufficient significance to warrant refusal of consent for development of the site.
6.6.5 However, given the assessed very high potential for previously unknown archaeological remains of Medieval origin to be encountered at the site due to the location of ridge and furrow earthworks within the site boundary it is probable that earlier archaeological potential may be preserved beneath the areas of ridge and furrow.
6.7 Ground Conditions
6.7.1 A Geo-Environmental and Geotechnical Assessment was undertaken by the Earth Science Partnership (report ref.: ESP.7600t.3441) for the proposed development. The assessment identified that the site contains Made Ground which presents a moderate to low potential contamination source.
6.7.2 Gas monitoring for the site is ongoing. The site lies within a radon affected area with less than 1% of properties above the action level, therefore, no radon protection is required. Laboratory testing has indicated that the fine-grained soils at shallow depth are of medium to high volume change potential presenting a high to moderate potential for shrinkage or swelling. The geotechnical assessment additionally identified a high to moderate potential for sulphate attack on buried concrete, therefore requiring advanced concrete classification.
6.7.3 The Earth Science Partnership recommends the following further investigation and/or assessments:
• Continued gas monitoring followed by ground gas assessment to determine risk posed by hazardous ground gases at the site and the implications on building designs;
• Selection of appropriate concrete class to mitigate against potential sulphate attack;
• Careful design of raft foundations to achieve require bearing requirements;
• Mitigation measures against potential shrinkage/swelling of the shallow soils;
• Detailed design for any earthworks/bunds to be constructed;
• Re-measure California Bearing Ratio (CBR) values at sub-grade prior to pavement construction;
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• Assessment of sensitivity of CBR value with changes in moisture content;
• Verification testing of any soils imported to site (if required); and
• Materials management plan for re-use of soils on site.
6.8 Flood Risk and Drainage
6.8.1 The proposed development site lies in an area designated by the Environment Agency as Flood Zone 1 and is outlined to have a chance of flooding of less than 1 in 1000 (0.1%) in any year.
6.8.2 The flood risk assessment (FRA) demonstrates that the requirements of the Sequential Test have been met, with the location of the site within land assessed as being outside of the 1 in 100-year (1%) event and ‘Less Vulnerable’ classification of the development.
6.8.3 The flood risk assessment has considered multiple sources of flooding and concluded the following:
Source Level of Risk
Fluvial Negligible
Tidal Very Low
Surface water Low- High
Sewer Low
Groundwater Low- Medium
Artificial Sources Low
6.8.4 The proposals will follow best practice regarding site drainage to ensure that any surface water runoff from the development is managed, ensuring flood risk is not increased elsewhere.
6.8.5 The proposed development will only result in a negligible increase to the impermeable area on-site, with the resultant runoff from the site containing pollutants. As such, it is proposed that surface water will be captured and utilised on-site within the AD process.
6.8.6 Discharge from the AD facility will be captured within a network of perforated filter drains, leachate water drainage, process water drainage and surface formed channels as per the existing scenario and discharged to the rainwater / effluent lagoons in the southern section of the site.
6.8.7 A Detailed Drainage Assessment / Strategy has been produced as an appendix to the FRA.
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6.8.8 Overall, taking into account the points stated in the FRA, the development of the site should not be precluded on flood risk grounds.
6.9 Noise
6.9.1 A Noise Impact Assessment was undertaken for the proposed development which considered the construction and industrial/commercial noise from the proposals. The assessment has been informed by unattended noise monitoring to characterise the background acoustic environment at nearby sensitive receptors to the north, east, south and west of the proposed facilities. The monitored LA90, T levels have been used to determine the representative background levels used in the assessment.
6.9.2 An indicative construction noise assessment has been undertaken for the site. No exceedances above the noise impact threshold have been predicted during the construction phase. A number of examples of Best Practicable Means have been included in this report which are proposed to be implemented on site to further reduce any noise impact on the local residents during the construction works.
6.9.3 Industrial/commercial sound associated with the operation of the AD plant facilities has been assessed using the methodology described in BS4142:2014+A1:2019. The assessment shows the predicted rating levels at nearby sensitive receptors do not exceed the representative background levels for the majority of the considered activities, with the exception of some exceedances expected during the operation of the biogas upgrading and CO2 recovery unit during the night-time periods; various additional noise mitigation measures have been proposed in order to reduce noise levels during these activities. Predicted rating levels after the implementation of the mitigation measures will be equal or below the background levels and therefore this will result in residual noise impacts of a negligible magnitude (adverse impacts for nearby residential receptors are unlikely).
6.9.4 Therefore, from a noise perspective the site is considered suitable for the intended use with no detrimental effects on the local community.
6.10 Odour
6.10.1 An Odour Assessment was undertaken for the proposed development in order to assess the potential odour impacts of the proposed improvements and extension to the Castle Eaton AD plant.
6.10.2 An assessment of the effects and significance of odour impacts from the proposed development using the IAQM methodology shows a prediction of negligible impacts at all receptors, apart from at two units at the Poplar Business Park (Receptors 10 (R10) and 11 (R11)) where slight adverse effects are predicted.
6.10.3 However, an assessment of the net effects of the proposed developments, arrived at by comparing the existing and future scenarios, shows negligible impacts at all receptors, apart from R11, were a “slight beneficial” impact or changes is predicted due to the relocation of silage clamps. 31 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
6.10.4 Overall, it is considered that the proposed development will have a negligible net odour impact at local receptors, and slightly beneficial effects at the closest commercial receptors.
6.10.5 The Odour Assessment therefore concluded that odour does not represent a material or significant constraint on the proposed development.
32 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
7 CONCLUSION
7.1.1 The proposed development seeks to upgrade and extend the existing plant and equipment to meet current industry standards, as well as allow for increased retention time of substrate in the digestion process. This will ensure an increased gas yield and enable future gas to grid connectivity. There are significant benefits brought by the applicant to assist the UK in meeting its low emission targets and preparation for the eventual shift to a carbon neutral based economy by 2050, which is strongly supported by the NPPF and local policies as well as the Overarching National Policy Statement for Energy (EN-1).
7.1.2 Importantly the development would provide the following benefits:
• Enhancements across the site including new and supplementary hedgerow planting, planting of new trees and shrub, peripheral habitat will be seeded and managed as wildflower meadows and a reptile hibernaculum will be created on the site;
• Improve the retention time of substrate in the digestion process with associated improved control of digestate quality and related issues such as odour;
• Improved site infrastructure to meet current environmental standards;
• Improved economic efficiency from the plant; and,
• Allowing the plant to be better equipped for gas export to the gas transmission system displacing natural gas use.
7.1.3 There are no statutory or non-statutory environmental designations which fall within or immediately adjacent to the site nor are there any designated heritage assets located within the site boundary. The site is not located within an area of significant landscape value and the site is well screened by existing vegetation.
7.1.4 There will be no change to the number of vehicle movements generated by the site and the existing site access is suitable. No exceedances above the noise impact threshold have been predicted during the construction phase and the predicted rating levels at nearby sensitive receptors do not exceed the representative background levels for the majority of the operational activities. It is noted that some exceedances expected during the operation of the biogas upgrading and CO2 recovery unit during the night-time periods however these would be within acceptable levels during the day and with the introduction of appropriate mitigation measures would also be below or equal to the background levels measured for properties during night time.
7.1.5 The accompanying environmental and technical reports cover each of the key disciplines in greater detail and demonstrate compliance with both local and national policy. The proposed development is therefore considered to be acceptable in regard to these planning, environmental and all other material considerations.
33 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
APPENDIX A – COUNCIL PRE-APPLICATION RESPONSE
34 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
Non Householder Pre Application Advice Report
Swindon Borough Council Pre Application Advice
PRE-APPLICATION REPORT
Application Ref: S/PMIN/20/0991 Date of enquiry: 6th August 2020 Date of report 23rd September 2020 issue: Site Address: Anaerobic Digester Unit, Castle Eaton Farm, Mill Lane, Castle Eaton Proposal: Proposed alterations to existing Anaerobic Digestion Plant including the erection of 1 no. additional digester, erection of a welfare/office building, weighbridge and other associated works. Planning Case Tom Buxton Telephone No: 01793 466240 Officer: Email address: [email protected]
Proposal Summary The pre-app proposes a number of alterations to the existing plant to include the erection of an additional anaerobic digester in order to make more efficient use of the land and increase gas yield.
Site Planning History The site has benefitted from a number of relevant planning approvals over the past 8 years, starting with the original permission for two digesters in 2012 (under consent S/12/0317), including a permission for a third digester in 2014 (under consent S/14/1308) and most recently a permission for the erection of a carbon capture plant (under consent S/17/ 0718).
Relevant Local Plan Policy
Adopted Swindon Borough Local Plan (SBLP) 2026
Policy DE1 – High Quality Design
Policy EN5 – Landscape Character and Historical Landscape
Policy EN7 – Pollution
Policy EC1 – Economic Growth through Existing Business and Inward Investment
Policy EC5 – Farm Diversification
SD2 - The Sustainable Development Strategy Non Householder Pre Application Advice Report
Policy TR2 – Transport and Development
Policy IN4 – Low Carbon and Renewable Energy
Emerging Swindon Borough Local Plan 2036 The Council has published the Regulation 19 Proposed Submission Draft Version of the Local Plan for public consultation. The public consultation period finished at the end of January this year.
Technical Guidance on Parking Standards DCGN (2007)
Draft Parking Standards for New Development (May 2019) The Council have produced a draft parking standards document that has undergone a period of public consultation last year and will need to go back before Planning Committee before adopted. This is likely to happen later this month.
Landscape Character Area Supplementary Planning Guidance 2004 (SPG)
All Swindon policies, guidance are available online. https://www.swindon.gov.uk/info/20113/local_plan_and_planning_policy/651/planning_policy_guidance/2
Relevant National Policy National Planning Policy Framework (NPPF)
Planning Practice Guidance
Principle of Development Swindon Local Plan Policy SD2 (The Sustainable Development Strategy) sets out the overall development strategy for the borough. The policy seeks to promote sustainable development within the settlement and urban boundaries of the borough whilst protecting the best of the countryside. The proposed site is located outside the Swindon Urban Area and Castle Eaton settlement boundary. Local Plan Policy SD2 states: development proposals in rural and countryside locations outside the rural settlement boundaries will be permitted where: * local needs have been identified and allocated through a Neighbourhood Plan or Neighbourhood Development Order; and/or * it supports the expansion of tourist and visitor facilities in appropriate locations where identified needs are met by existing facilities in a rural service centre; or * It is in accordance with other policies in this Plan permitting specific development in the countryside
Non Householder Pre Application Advice Report
Paragraph 83 of the NPPF states that planning decisions enable the sustainable growth and expansion of business in rural areas (through conversion of or well-design new buildings) and the promotion of the development and diversification of agricultural and other land-based rural businesses. The NPPF objective is reflected in Local Plan policies EC1 (Economic Growth through Existing Business and Inward Investment) and EC5 (Farm Diversification). Policy EC1 seeks to promote inward investment and the growth and retention of existing business. The policy also states opportunities to develop employment sectors including (inter alia) ‘low carbon development and manufacturing at appropriate locations and in conjunction with Policy IN4’ will be particularly supported. Policy IN4 (Low Carbon and Renewable Energy) states that low carbon and renewable energy infrastructure which has benefits for local communities and the local economy will be encouraged and supported, and will be assessed under national policies and against the following: * Social and economic benefits (including local job creation opportunities); * The impacts on, and benefits to local communities; and; * Environmental impact
The proposed development is part of an operational renewable energy site and whilst itself not a low carbon energy development, it is understood that the proposal will reduce greenhouse emissions from the anaerobic digestion process, resulting in no carbon dioxide emissions from the plant. The social and economic benefits in terms of job creation will need to be considered when the full application is submitted. It is however apparent that the proposal will allow the growth of an existing rural business and there will be benefits to the environment and local community through reduced greenhouse gas emissions. Furthermore, the NPPF paragraph 148 requires that the planning system supports the transition to a low carbon future through helping to reduce greenhouse gas emissions and encouraging the reuse of existing resources.
Policy EC5 (Farm Diversification) applies, and states that proposals for economic activities that bring about farm diversification, as defined by the EU, shall normally be permitted, providing that: * The proposals are operated as part of a viable farm holding and contribute to the viability of the holding; * It is not detrimental to the character and appearance of existing buildings and their setting within the Landscape Character Area; * Existing buildings are used in preference to new buildings or extensions; * Utilities and other infrastructure is available or can be provided; and * There is access by means of an existing road; no traffic hazards are created or increased; and road improvements incompatible with the character of the surrounding area are not required.
From the information provided it is deemed likely that the LPA will consider the principle of the development favourably. Clearly there are a number of other key considerations that are set out below.
Highway Expectations The Highway Officer has provided the below comment.
I note the submission by the applicant of a Pre-Application Report and accompanying appendices. These documents inform the views expressed below. Given current working conditions, I have not been able to visit the site but will do so before providing any comment on an application for planning permission.
Non Householder Pre Application Advice Report
The Pre-Application Report helpfully includes a description of the site and an explanation of the current and proposed operation of the Anaerobic Digestion Plant. From this information I can provide a preliminary view as to the issues relevant to the local highway authority, although further detail on both these matters (as described below) will be necessary to allow an application for planning permission to be fully assessed on behalf of the local highway authority. Whilst the site of the proposal is relatively inaccessible, this is not a land use inappropriate for a relatively rural location and I have no in-principle objection to the proposal. The issue for the local highway authority will be the extent to which the proposals give rise to new or different movements (whether by car, by commercial vehicle, on foot or by bicycle) and where this is the case, whether the existing highway network can safely and effectively accommodate those additional movements. A second issue concerns the ability of the site to accommodate parking and manoeuvring without impact on the operation of the adjacent highway. I note and welcome the commitment expressed within the Pre-Application Report to submit a Transport Statement with any application for planning permission. In addressing the highway issues, the Statement will be expected to set out:
The layout of the site, its means of access (by all modes) and the current arrangements for parking and turning; What the current pattern of vehicle activity of the site is, in terms of vehicle numbers and type, differentiating between staff, visitors and operational activities; What the anticipated pattern of vehicle activity would be, in terms of numbers and vehicle type; Existing and future movements by staff on foot and by bicycle; An assessment of the adequacy of the highway network to accommodate any new walking and cycling trips; The directional distribution of new vehicle movements; Based on the above, an assessment of the adequacy of the highway network to accommodate any additional vehicle movements; An assessment of anticipated car, cycle and commercial vehicle parking demand and the ability to accommodate it; An assessment of on-site manoeuvring needs and the ability to accommodate it;
I have no reason to believe that any of the assessments defined above will indicate issues of concern but I can only be sure of that if the assessments are carried out. If it would be helpful, the Highway Officer has advised that they will gladly engage the applicants transport consultant to clarify any uncertainties before the Transport Statement is prepared.
Landscape The site is located within the designated Thames Valley landscape character area. As a result Policy EN5 is of direct relevance which affords the area specific landscape protection seeking to protect it from inappropriate development. The Policy details that regard should be had to the relevant Landscape Character Assessment. The NPPF, at section 15 also sets out the requirement to protect valued landscapes.
Whilst no landscape based objections are raised at present this is on the basis of the information currently available, with there being no full elevation plans/sections etc available. Although it is acknowledged that the majority of the proposed equipment will be largely viewed with the backdrop of existing buildings and digesters the impact of the new buildings and equipment on the surrounding area will be a key consideration of any such future application. Non Householder Pre Application Advice Report
In support of any such future planning application an appropriately detailed Landscape and Visual Impact Assessment would be required in order to show how the scheme may fit into the landscape. The existing plant and the existing solar panels are appreciated however it would be most helpful for an overview as to who may see these elements and, if necessary, how they might be screened. This is especially important in respect of users of the adjacent public right of way.
The Landscape Officer has detailed that he does not necessarily want a wide ranging LVIA but one that is specifically focussed on the issues arising from this particular scheme.
Amenity Policy DE1 of the adopted SBLP requires consideration of amenity in terms of noise and smell pollution (amongst other things). Policy EN7 of the adopted SBLP refers specifically to pollution and requires developments to not result in loss of amenity for existing land uses. The Environmental Health Officer has been consulted regarding this pre-application however is not able to offer any meaningful advice until the submission of the identified odour and noise/vibration assessments. Clearly we would need to be content that the proposals would not cause an unacceptable impact to the amenity of the area with specific reference to residential properties, in particular the closest ones which sit approximately 350 metres away to the north. In this case the potential impact could arise from the operations proposed on site but also associated vehicle movements to and from it.
Archaeology The County Archaeologist has been consulted and has advised that: Having reviewed our records and considering the scale of impact likely to be created by the proposals, I can confirm that there are no archaeological issues that I would wish to raise in this instance.
Drainage To follow
Ecology To follow
Other Consultation with the Parish Council and Ward Councillors is recommended prior to the submission of s full application.
Conclusions It is deemed likely that the LPA will be in a position to be supportive of the principle of the development however it is not possible at present to make a full assessment of the full landscape and amenity impact based on the level of information currently submitted.
Disclaimer It is important to note that there are limits to the pre application advice that can be given by officers. The pre application advice service is not a passport to getting permission for inappropriate planning Non Householder Pre Application Advice Report
proposals. Planning legislation requires that all decisions on planning applications must be taken in accordance with the Development Plan, unless material considerations indicate otherwise. In certain cases a planning application will be referred to Planning Committee for determination. The advice given by officers does not bind elected members in their decision-making.
APPENDIX B – POLICY ASSESSMENT
Adopted Swindon Borough Local Plan (SBLP) 2026
Swindon Borough Local Plan Assessment of Proposed Development
Policy SD1 – Sustainable Development Principles Through the generation of a renewable energy in the form of biomethane, the proposed development ‘To enable the delivery of sustainable development and support sustainable delivers a sustainable development that helps to communities in the Borough all development proposals will: address the impact of climate change, respects the be of high quality design; promote healthy, safe and inclusive communities; natural and historic built environment, contributes to • respect, conserve, and/or enhance the natural, built and historic the provision of energy infrastructure and helps to environments; support jobs in the local area through both construction and operation. • assess and address the impact of climate change through mitigation and/or adaption measures; The upgrade and extension of the existing plant improves the efficiency of the land use to create a • provide or contribute to the assessed local and borough wide infrastructure development that would be fit for purpose in meeting and service requirements; current industry standards and EA requirements. • contribute to the retention of jobs and growth of the local economy and As such it is considered that the proposed complement Town Centre regeneration; development complies with this policy. • be accessible by walking, cycling and/or public transport; and, • use land and resources (such as water, energy, minerals and waste) in an efficient and effective way.’
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Swindon Borough Local Plan Assessment of Proposed Development
Policy SD2 – The Sustainable Development Strategy The proposed development will enable the expansion and diversification of an existing agricultural business ‘Outside Swindon: enterprise and complies with this policy. development proposals in rural and countryside locations outside the rural settlement boundaries as shown on the Policies Map will be permitted where: • it is in accordance with other policies in this Plan permitting specific development in the countryside.’
Policy SD3 – Managing Development The proposed development is in accordance with polices within the Local Plan and improves the a. ‘When considering a development proposal, the Council will take a positive economic, social and environmental conditions of the approach to reflect the presumption in favour of sustainable development.’ site.
Policy DE1 – High Quality Design The proposed development has been designed to optimise the use of the available area. Allowing for ‘Proposals for development should address the objectives of sustainable increased retention time of substrate in the digestion development through high quality design and place-making principles’ process and therefore increased gas yield and enable future gas to grid connectivity.
The incorporation of the gas upgrade plant will allow for the plant to export biomethane into the gas transmission system, thereby displacing natural gas. Fuel substitution in this way supports the de- carbonisation of the hard-to-reach sector of domestic cooking and heating, therefore supporting the UK’s legally binding target of achieving net zero by 2050.
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Swindon Borough Local Plan Assessment of Proposed Development
As such it is considered that the proposed development complies with this policy.
Policy DE 2 – Sustainable Construction The layout of the proposed development has been formulated in the main by a process driven need, a. ‘Development shall demonstrate passive solar benefits, (heating, however the design has made the most efficient use ventilation, cooling and lighting) in accordance with Policy DE1, through the of the land available to ensure that it is sustainable and layout and design of the site, and orientation and design of buildings.’ meets the Construction Industry Research and Information Association (CIRIA) and Sustainability Assessment of Food and Agriculture Systems (SAFA) guidelines. As such it is considered that the proposed development complies with this policy.
Policy EN1 – Green Infrastructure Network New trees and shrubs will be planted on the north and west boundaries of the existing AD plant as well as a. In accordance with the Swindon Borough Green Infrastructure Strategy around the edge of the proposed infrastructure in the development shall protect and enhance green infrastructure and assets as southern site extension. identified in Appendix 4. This includes the requirement that development must provide for the protection and integration of visually or ecologically Following a Hedgerow Assessment the proposed important existing trees, hedges and woodlands. Development that would development seeks to retain a hedgerow on site that result in the loss or deterioration of irreplaceable habitats, including qualifies as important under the ecological criteria of ancient woodland and the loss of aged or veteran trees found outside the Hedgerow Regulations 1997. ancient woodland will only be permitted where the need for, and benefits The existing hedgerows towards the site access will of, the development in that location clearly outweigh the loss. be supplemented by additional hedgerow planting filling any gaps. New hedgerows will also be planted
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Swindon Borough Local Plan Assessment of Proposed Development
b. Development shall provide and design green infrastructure to integrate on the western boundary of the site’s southern with existing green corridors identified on the Policies Map, to maximise extension as well as to the south of the proposed its connections and functions and ensure the sustainable maintenance and silage clamps. management of it. Wildflower grassland will be created on the periphery of the AD plant, the earth bank and in the southern section of the extended AD plant to create a species- rich sward of flowering herbs and grasses typical of species-rich lowland meadow.
As such it is considered that the proposed development complies with this policy.
Policy EN2 – Community Forest The proposed development will retain all tree cover on site as well as propose additional planting in the form ‘Community Forest Development shall contribute towards the aims and of trees and hedgerow. Further detail is provided objectives of the Great Western Community Forest (GWFC) in Swindon. This within the EcIA, LEMP and BNG calculations which will be achieved by: ensuring a net increase in tree cover through the planting accompany this planning application. of new woodland and trees; creating or enhancing habitats for biodiversity, including built structures in accordance with Polices EN1 and EN4; and As such it is considered that the proposed ensuring access to local woodlands and opportunities for communities and development complies with this policy. businesses to benefit from GWCF.’
Policy EN4 – Biodiversity and Geodiversity The proposed development, without any mitigation, would be anticipated to have, at most, adverse a. ‘Development will avoid direct and indirect negative impacts upon significant effects at the local level only. However, with biodiversity and geodiversity sites as identified on the Policies Map. This the implementation of the mitigation and will be achieved through sensitive site location and layout, and by enhancements outlined within the accompanying maintaining sufficient buffers and ecological connectivity with the wider 38 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
Swindon Borough Local Plan Assessment of Proposed Development
environment. Damage or disturbance to local sites will generally be EcIA, the proposed development is not anticipated to unacceptable, other than in exceptional circumstances where it has been result in any significant adverse residual effects to the demonstrated that such impacts are: unavoidable and reduced as far as important ecological features found on the site. possible or are outweighed by other planning considerations in the public The accompanying Hedgerow Assessment helped interest, and where appropriate compensation measures can be secured. inform the design of the development which seeks to b. All development, where appropriate shall protect and enhance biodiversity retain a hedgerow on site that qualifies as important and provide net local biodiversity gain. Where this is demonstrably not under the ecological criteria of the Hedgerow achievable, mitigation and compensation measures will be agreed.’ Regulations 1997. The accompanying biodiversity assessment concludes that with the inclusion of landscape and ecological enhancement measures the proposed development the proposed development will result in a change of +0.42 biodiversity area units (+3.29%) and +2.72 terrestrial linear biodiversity units (+59.65%). As such it is considered that the proposed development complies with this policy.
Policy EN5 – Landscape Character and Historical Landscape The Landscape and Visual Appraisal undertaken for the proposed development describes the site as being ‘Proposals for development will only be permitted when: in a reasonable condition with some aesthetic and the intrinsic character, diversity and local distinctiveness of landscape within naturalistic features, with the topography of the site Swindon Borough are protected, conserved and enhanced; being representative of the local landscape character,
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Swindon Borough Local Plan Assessment of Proposed Development
the design of the development and materials used are sympathetic to the as well as the existing framework of ditches, mature surrounding landscape; trees and hedgerows. unacceptable impacts upon the landscape are avoided; and, where other The northern half of the site is already established as negative impacts are considered unavoidable, they are satisfactorily mitigated. an AD plant with the extension area consisting of an arable field. The majority of the southern and eastern In meeting the requirements of EN5a, applicants for development should perimeter is a mature maintained hedgerow, with demonstrate how they have taken into account Landscape Character occasional mature trees. The site is privately owned Assessments.’ with no public access. The site is not within land designated either locally or nationally. Based upon the stated features of the site, its current condition, use and location, the site is assessed as being of medium landscape value. With regard to the Swindon Landscape Character Assessment, the site is located within local landscape type ‘Thames Vale’ and the identified key characteristics of this landscape type are present within the site and its immediate vicinity. The study area is not covered by designated landscapes. The Castle Eaton Conservation Area is within the study area, but outside the Zone of Theoretical Visibility (ZTV) for the proposed development. As such it is considered that the proposed development complies with this policy.
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Swindon Borough Local Plan Assessment of Proposed Development
Policy EN6 – Flood Risk The Flood Risk Assessment undertaken is consistent with Local Planning Authority requirements and A. The risk and impact of flooding will be minimised through: accords with Policy EN6. It complies with the NPPF • directing development to areas with the lowest probability of flooding; and PPG and demonstrates that flood risk from all • ensuring that all development addresses the effective management of all sources has been considered in the proposed sources of flood risk; development. • ensuring that development does not increase the risk of flooding elsewhere including on adjoining and surrounding land; and • ensuring wider environmental benefits of development in relation to flood risk.
B. The suitability of development proposed in flood zones will be assessed using the Sequential Test, and, where necessary, the Exceptions Test. A sequential approach should be used at site level. C. A site specific flood risk assessment will be required for development proposals of one hectare or greater in Flood Zone 1 and for all proposals for development (including minor development and change of use) in Flood Zones 2 and 3 and Critical Drainage Areas, and also where proposed development or a change of use to a more vulnerable class may be subject to other sources of flooding. Appropriate mitigation and management measures must be implemented. D. All development proposals must be assessed against the Local Flood Risk Management Strategy to address locally significant flooding including that
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Swindon Borough Local Plan Assessment of Proposed Development
affecting neighbouring authorities. Appropriate mitigation and management measures must be implemented.
E. All development shall be required to provide a drainage strategy. Developments will be expected to incorporate sustainable drainage systems and ensure that run-off rates are attenuated to greenfield run-off rates. Higher rates would need to be justified and the risks quantified. F. Sustainable drainage systems should seek to enhance water quality and biodiversity in line with The Water Framework Directive.
Policy EN7 – Pollution The Odour Assessment undertaken considers that the proposed development will have a negligible net ‘Development that is likely to lead to emissions of pollutants such as noise, odour impact at local receptors, and slightly beneficial light, vibration, smell, fumes, smoke, soot, ash, dust, grit or toxic substances effects at the closest commercial receptors. that may adversely affect existing development and vulnerable wildlife habitats, shall only be permitted where such emissions are controlled to a point The Noise Assessment that accompanies the where there is no significant loss of amenity for existing land uses, or habitats.’ application states that at all sensitive receptors the rating level does not exceed the background level and
therefore adverse impacts due to noise are unlikely. Notwithstanding this, mitigation has been proposed in the form of restricted timing of deliveries and a reflective acoustic fence around the biogas upgrader. As such it is considered that the proposed development complies with this policy.
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Swindon Borough Local Plan Assessment of Proposed Development
Policy EN8 – Unstable Land A Geo-Environmental and Geotechnical Assessment identified that the site contains Made Ground which a. Development of land that is either known to be unstable, or is strongly presents a moderate to low potential contamination suspected of instability, shall only be permitted when: an evaluation source. has been submitted of the level and precise nature of any instability; and there are no significant adverse effects on adjacent sites; and the Gas monitoring for the site is ongoing. extent of remedial measure required to achieve a level of land stability The assessment recommends the following further suitable for the propose use, capable of supporting future development investigation and/or assessments: loads has been identified. • b. Where planning permission is granted, conditions may be imposed Continued gas monitoring followed by ground requiring the execution of any necessary remedial works. gas assessment to determine risk posed by hazardous ground gases at the site and the c. Where a site is affected by land stability issues responsibility for implications on building designs; securing a safe development rests with the developer and/or landowner, who will be required to carry out the above. • Selection of appropriate concrete class to mitigate against potential sulphate attack; Policy EN9 – Contaminated Land • Careful design of raft foundations to achieve a. Development of land that is either contaminated, or is strongly require bearing requirements; suspected of being contaminated, shall only be permitted when: • Mitigation measures against potential • an evaluation has been submitted of the level and precise nature of any shrinkage/swelling of the shallow soils; contamination and need for removal or treatment; • Detailed design for any earthworks/bunds to be constructed;
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Swindon Borough Local Plan Assessment of Proposed Development
• and the potential of existing contaminants to pollute both surface water • Re-measure California Bearing Ratio (CBR) and ground water, both during and after construction has been values at sub-grade prior to pavement established; construction. • and the decontamination measures required to achieve a level of land • Assessment of sensitivity of CBR value with quality suitable for the proposed end use have been identified; changes in moisture content. • and measures are taken to ensure that migrating gas is safely dealt with • Verification testing of any soils imported to site (if where development is proposed on land adjacent to an uncontrolled required). ‘gassing’ landfill site. b. Where planning permission is granted, conditions may be imposed • Materials management plan for re-use of soils on requiring the execution of any necessary remedial works. site.
c. Where a site is affected by land contamination responsibility for securing a safe development rests with the developer and/or
landowner, who will be required to carry out the above.
Policy EN10 – Historic Environment and Heritage Assets No important heritage assets are identified within the site boundary and as such no specific direct impacts a. ‘Swindon Borough’s historic environment shall be sustained and have been identified as likely to arise from the enhanced. This includes all heritage assets including historic proposed development of sufficient significance to buildings, conservation areas, historic parks and gardens, landscape warrant refusal of consent for development of the site. and archaeology. However, given the assessed very high potential for b. Proposals for development affecting heritage assets shall conserve previously unknown archaeological remains of and, where appropriate, enhance their significance and setting. Any Medieval origin to be encountered at the site due to harm to the significance of a designated or non-designated heritage the location of ridge and furrow earthworks within the asset, or their loss, must be justified. Proposals will be weighed against site boundary it is probable that earlier archaeological the public benefits of the proposal, whether it has been demonstrated 44 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
Swindon Borough Local Plan Assessment of Proposed Development
that all reasonable efforts have been made to sustain the existing use, potential may be preserved beneath the areas of ridge find new uses, or mitigate the extent of the harm to the significance of and furrow. the asset; and whether the works proposed are the minimum required As such it is considered that the proposed to secure the long term use of the asset. development complies with this policy. c. Any alterations, extensions or changes of use to a listed building, or development in the vicinity of a listed building, shall not be permitted where there will be an adverse impact on those elements which contribute to their special architectural or historic significance, including their setting. d. Scheduled monuments and other nationally important archaeological sites and their settings will be preserved in situ, and where not justifiable or feasible, provision to be made for excavation and recording. Development proposals affecting archaeological remains of less than national importance will be conserved in a manner appropriate to their significance. An appropriate assessment and evaluation should be submitted as part of any planning application in areas of known or potential archaeological interest.
e. Development within or which would affect the setting of the Borough’s Conservation Areas will conserve those elements which contribute to their special character or appearance.
f. Features which form an integral part of a Park or Garden’s historic interest and significance will be conserved and development will not detract from the enjoyment, layout, design, character, appearance or
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Swindon Borough Local Plan Assessment of Proposed Development
setting of them, including key views into and out from, or prejudice future restoration. g. Any development proposal that would affect a locally important or non- designated heritage asset, including its setting, will be expected to conserve its significance, and any harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.’
Policy EC1 – Economic Growth through Existing Business and Inward The proposed development includes the upgrade of Investment existing plant and equipment on the site. The energy produced from the development is low carbon, ‘Policy EC1 seeks to promote inward investment and the growth and retention sustainable and renewable and is therefore of existing business…The policy states opportunities to develop employment supportive of national objectives to de-carbonise the sectors including (inter alia) ‘low carbon development and manufacturing at UK’s energy supply. appropriate locations and in conjunction with Policy IN4’ will be particularly supported.’ As such it is considered that the proposed development complies with this policy.
Policy EC5 – Farm Diversification SD2 - The Sustainable Development Strategy The proposed development will enable the expansion and diversification of an existing agricultural business ‘In rural areas, proposals for economic activities that bring about farm enterprise. diversification (as defined by the EU) shall normally be permitted, providing that: the proposals are operated as part of a viable farm holding and contribute As such it is considered that the proposed to the viability of the holding;’ development complies with this policy.
Policy TR2 – Transport and Development The existing access to the site will be retained and the volume of traffic associated with the existing
46 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)
Swindon Borough Local Plan Assessment of Proposed Development
a. ‘Development shall be permitted where proposals provide access that development will remain unchanged with the site is appropriate to the scale, type and location without detriment to upgrade and extension. highway safety and local amenity, and where there is an existing safe As such it is considered that the proposed and convenient pedestrian and cycle access or provision is made for development complies with this policy. such access.’
Policy IN4 – Low Carbon and Renewable Energy The energy produced by the AD plant will be low carbon, sustainable and renewable as it recovers ‘Energy efficiency and low carbon energy generation schemes brought forward energy from agricultural waste material. The residual by communities, or with major community benefits, will be encouraged and ‘digestate’ produced can then be used as a soil supported in principle.’ improver, reducing the requirement for use of Policy IN4 aims to contribute to this and to facilitate a secure, sustainable and inorganic chemical fertilisers which are known to have affordable energy supply for communities and businesses in Swindon a higher carbon footprint. Borough. The policy seeks to achieve an increase in the level of renewable As such it is considered that the proposed energy generation in Swindon Borough through integrating renewable / low development complies with this policy. carbon energy in new development and providing a positive framework for considering large scale proposals for renewable/low carbon development.
47 Biomethane (Castle Eaton) Limited Castle Eaton AD Plant Upgrade and Extension Planning Design and Access Statement 662939-01 (03)