One of the first main reactions the people (and Galway County Council) have had to the proposed BioGas Plant in Gort  is ‘Why on earth is it being proposed here?’   There are a number of themes emerging around this.

• South Galway is a very scenic area and has huge potential for tourism growth so why threaten this with dodgy smelly Biogas plant (See Track Record)
• South Galway/North Clare is a unique area with one of the highest concentrations of SACs in Ireland so why build a plant that could devastate these areas?
• South Galway is prone to unpredictable and devastating flooding, that seems to be increasing in frequency and severity – Why on earth would you then build a Biogas plant within 10m of the Gort River?
• This development significantly contradicts the Gort Local Area Plan 2013-2109 so why should it be allowed to proceed?

Location, Location, Location

Biogas plans are supposed to be close to feedstock source as well as having a suitable land bank to spread the digestate end product (akin to slurry). The Gort Biogas Environmetal Impact Assessment Report (EIAR) indicates that there is a lot of unsuitable land for feedstock supply and digestate removal in summary.

If we superimpose unsuitable land SACs, SPAS and flooding we get something like this.

The dark green is where the potential source for feedstock and target for digestate – The Red Cross in the middle is where they want to build the proposed Gort Biogas plant right in the middle of unsuitable land, Special Areas of Conservation, and flood plains!

So what is the justification of locating the Biogas plant in this area seeing S South Galway/North Clare doesn’t have the highest concentration of cattle.  According to Table 2.3 the estimated volume of slurry arising from this total area in the circle is 471,361M3. From this map most of this would be in the  areas north and south of the catchment zone shown.   According to Table 2.2, of the total land within the 30k radius,  11% of it is within the 10k zone. If we average out slurry estimations, the area within 10km of the plant would be generating over 47,000 tons of slurry.  The EIAR (VOLUME 2) states “The biodegradable feedstocks will primarily comprise grass silage and organic farm-based residues such as animal slurry which will be sourced from farms in the vicinity of the plant.   As part of feedstock supply arrangements with local farmers, digestate will be delivered back to the local farms, thereby recycling nutrients to agricultural lands.”

If digestate is disposed of in the vicinity of the plant (10K)  then while this area normally caters for 47,000 tons of slurry, it may now have to contend with a tonnage exceeding 150,000 tons (120,000 tons of digestate and slurry) .   The bottom line is that while feedstock may come from various locations the digestate could be concentrated heavily within the 10km radius and this could have significant impacts on overlying areas.  This analysis has not been done as part of the EIAR.

The referenced EIAR only offers alternate locations around Gort – Why? Why not in farm-rich communities that have more concentration of pasture-land and lifestock.

This proposed location of the Biogas plant is unsuitable and no reaonable alternatives have been proposed -therefore this application should be refused.

Misalignment to Gort Local Area Plan 2013-2019:

The Gort Local Area plan outline a strategy for development ( http://www.galway.ie/en/media/Gort%20Local%20Area%20Plan%202013-2019.pdf) and is a land use plan and overall strategy for the development of Gort.  In general, it helps to guide the local authority and permit development where it is satisfied that the suggested form of development will be compatible with the policies and objectives for the specific zones.

The proposed site is not in the Local Area Plan and is currently zoned for agricultural use and therefore it not compatible with the LAP.  The site however does have an impact on Gort’s objectives. The following is a reasonable assessment on how the BioGas plant impacts the Gort LAP Strategy.

Guiding Principles	Biogas plant Impact	Comment
Realising the town’s potential as a „Key Town‟ as set out in the Galway County Development Plan and attracting and planning for the population target established in the Core Strategy up to 2015 and beyond.	Very Negative	Feedstocks, digistate,  smells and additional traffic is not generally seen as something that attracts population
Reflecting the needs and aspirations of local communities, businesses and other interested and affected groups, as expressed through the public consultation process.	Very Negative	The Local community clearly doesn’t want a biogas plant in this location as was seen by an attendance of 300 people at a public meeting in December 2019
Promoting sustainable land use and transport by capitalising on the opportunity presented by the delivery of the new M18 Gort to Crusheen motorway, the Ennis-Athenry section of the Western Rail Corridor so that sustainable travel, including walking and cycling, and integrated land use and transportation become central to the development of new neighbourhoods and the future development of Gort.	Very Negative	Current walking routes (unaddressed by EIAR) will be impacted by Biogas plant.  Additional HGVs coming through town increase risk of accidents and will not promote walking/cycling safely around Gort
Maintaining a strong and vibrant town centre that sustains the ability to attract new businesses and meets the retailing and service needs of the town and its surrounding hinterland, in addition to offering a pleasant and attractive environment for shopping, business, recreation and living.	Very Negative	Biogas plant, flares, steam etc and potential 100+ HGVs a day does not promote attractive environment for shopping, business and recreational living
Facilitating the provision of a range of facilities, amenities and supporting services to serve the needs of the town, including educational, recreational, religious, social, community and civic requirements for children, youths, adults and the elderly.	Very Negative	Biogas plant does not offer any services, needs here. The plant is purely for profit and not the needs of the community
Fostering economic development and employment creation by optimising the potential of the town‟s strategic location and enhancing Gort as a place of employment through the provision of a positive and flexible framework for the creation of new employment opportunities.	Negative	A site of 22 acres close to Gort providing just a handful jobs is a tactical and not a strategic result
Supporting the delivery of support infrastructure necessary to facilitate the future growth and sustainable development of the town.	Very Negative	Biogas plant will add additional pressure on infrastructure.  Water requirements are missing.
Promoting strong community spirit, social inclusion, civic pride and local identity for the town within the broader rural area surrounding Gort.	Very Negative	Local community doesn’t want Gort associated with Slurry and industrial plant
Protecting and enhancing the heritage and character of Gort including the natural assets, environment, built heritage, public realm, local character and amenity, for the benefit of current and future generations.	Very Negative	Biogas plant does not offer any heritage aspects, doesn’t add to local character and is not beneficial for future generations

The LAP also calls out the Tourism potential

“Tourism is an important element of Gort‟s local economy and is a sector that has the potential for further growth. The cultural, built and natural heritage of the town and significant local tourist amenities such as Coole Park, Thoor Ballylee, Kilmacduagh monastic settlement and the town‟s proximity to the Burren are important tourist attractions and opportunities for further tourism development, which in turn can help to ensure the appropriate management and protection of Gort‟s local heritage and amenities.”

As part of the Economic Objective ED4:

Tourism Development (refer to Maps 2A/2B) Encourage and facilitate the sustainable development of the tourism potential of Gort and its environs in a manner that respects, builds on, protects and enhances the cultural, built and natural heritage of the town and the local amenities within the Plan Area. Key projects and initiatives that will be supported will include:

1. Support the sustainable development of a river walkway and a linear park including recreational facilities and activities that will benefit the local community and visitors to the area and enhance the tourism infrastructure in an environmentally sustainable manner that recognises the Water Framework Directive, water quality and Natura 2000 conservation management objectives for the Coole-Garryland Complex and associated protected species including otter and bat species.
2. Investigate the provision of a tourist/information centre within the town centre.

 

The maps show a Riverwalk titled ‘Provide a walkway along the Kinincha and Pound Road’ (TI24)

• Objective TI 24– Walkways (refer to Specific Objectives Maps 2A/2B) Provide a walkway along the Cannahowna/Gort River including the Kinincha and Pound Road in a sustainable manner where possible. Regard should be had to the protection of Otters and Otter breeding sites and resting places along the proposed river walk.Comment : Local community (Gort River Walk Development Group) has met with Galway County Council to progressing a Gort River Walk proposal and has received funding for phase 1 on the Lavally side. The   Proposed Biogas plant is a new development that will not promote or prioritise walking. The proposed Biogas plant, potential smells, noises,  and associated HGVs will have a significant impact on this objective.
• Objective TI4 – Walking : Facilitate the improvement of the pedestrian environment and network so that it is safe and accessible to all through the provision of the necessary infrastructure such as footpaths, lighting, pedestrian crossings, traffic calmed streets etc. New developments shall promote and prioritise walking, shall be permeable, adequately linked and connected to neighbouring areas, the town centre and train station, recreational, educational and employment destinations and shall adhere to the principles contained within the national policy document Smarter Travel: A Sustainable Transport Future – A New Transport Policy for Ireland 2009-2020 (and any updated/superseding document). Galway County Council will ensure that new lighting in sensitive areas, such as close to water-bodies or stands of broadleaved trees, will be sensitively designed so as to avoid impacts on foraging bats and other nocturnal wildlife. “

Comment : Local community has Proposed Biogas plant is a new development that will not promote or prioritise walking. It will detract from it and as such is at odds with this objective.

• Objective TI5 – Cycling Facilitate the improvement of the cycling environment and network so that it is safe and accessible through adequate traffic management and the provision of the necessary infrastructure, such as surface treatment, junction treatment, traffic calmed streets, cycle track/s, cycle lane/s, lighting, road crossings, etc. New developments shall promote and prioritise cycling, shall be permeable, adequately linked and connected to neighbouring areas, the town centre and train station, recreational, educational and employment destinations and shall adhere to the principles contained within the national policy documents Smarter Travel: A Sustainable Transport Future – A New Transport Policy for Ireland 2009-2020 and the National Cycle Policy Framework 2009-2020 (and any updated/superseding documents).

Comment : Proposed Biogas plant is a new development that will not promote or prioritise cycling. It will detract from it and as such is at odds with this objective.

Objective UI7 – The Cannahowna/Gort River and Drainage Catchment (refer to Specific Objectives Maps 2A/2B) Require new development proposals within the catchment of the Cannahowna/Gort River or that potentially drain towards this river to include full details of proposals to address the high probability of flooding associated with the river and its catchment and the need to provide adequate surface water drainage, including the incorporation of Sustainable Drainage Systems.

Comment : As shown the CFRAMS reports have self-assessd themselves as having low-confidence in predicting effects downstream from Gort Bridge.  The proposed Biogas plant is a new development has not addressed this adequately.

This proposal greatly contradicts the objectives in the Gort Local Area development plan and therefore the application should be rejected.

Odour!

The impacts of poor air quality would have a devastating affect on this area.According to report by Bioenergy research, 11 Biogas plants were studied and found to have had odour complaints.

Considering the addition of potentially 3-4 times the amount of digistate being added to lands in the vicinity of the plant this would have a significant impact on the smells and the welfare of people and tourists coming into the area.

https://www.google.com/search?client=firefox-b-d&q=does+biogas+smell

Track Record

The current biogas plants run by Glenmore Estates in Donegal has come under continusus scrutiny from the EPA due to non-complainces. Section 2.12 of EPA Site visit Report (Site visit reference number SV15392)

Odour sampling and analysis carried out in September 2017 on the Odour Control Stack A2-2 demonstrated a non-compliance (1,261 Oug/m3) with the emission limit value specified in the licence of 1,000 Oug/m3 for odour. This was not notified as an incident to the Agency.

Surface water monitoring results from January and February 2018 show elevated levels of parameters such as BOD and Ammonia which indicate the potential for environmental contamination of surface water. These results were not notified as incidents to the Agency, the Local Authority, Irish Water nor Inland Fisheries Ireland.

In fact, there has been so many non-complainces that Glenmore Estates has made it onto EPA’s National Priority Sites List for Enforcement

Glenmore Biogas Limited, Donegal has been identified by EPA as one of the National Priority Site for Enforcement for failing to meet the necessary environmental standards.

This kind of non-compliance could be devestating for the region and yet this plant went through similar EIAR process which doesn’t seem to guarauntee the level of due-diligence that is needed to ensure there are no unexpected impacts.  The lack of response to these EIARS is highly concerning.

 

BOOM!

According to the study ‘Analysis of accidents in biogas production and upgrading’, by Valeria Casson Moreno

Biogas industry is experiencing a fast growth worldwide, and biogas production is constantly increasing. However, the number of accidents in biogas production is growing even faster.

The paper states that the study results are  ‘an early warning concerning the major accidents hazard in biogas industry and rose the concern about the need of improving the safety culture and risk awareness in this sector, also by developing and adopting appropriate and specific safety standards.’

 

Given the current track record of the company behind the Gort Biogas Plant, there are significant concerns here.

Sensitivity

This area is very vulnerable to environmental incidents.  The Derrybrien windfarm produced a below-standard EIAR and proceeded with development that caused an environmental disaster of the Derrybrien landslide.  The ESB and Irish Government were subsequently charged by European Court of Justice.  The local community was highly active in this case and sees very similar dynamics with this development. The fact that the Biogas plant is in the middle of unpredictable flood plain and so close to the Gort River and its underground connectivity with several SACs, means that if any impacts is not 100% proven to be fully mitigated, the precautionary principle of the Habitats Directive mandates that the development should not proceed.

The current EIAR is not fit for purpose here with blatant holes, gaps, incorrect assumptions and lack of clear analsysis mandates that the application must be refused.

David Murray