Galway County Council has refused planning permission to the Biogas developers citing many reasons, one of which relates to concerns over traffic. The Biogas developers have come back and appealed the decision.

We think they have a blind-spot when it comes to traffic analysis.

Information Requests and planning Decision:

Even at the pre-planning meeting between Developers and Galway County Council on 9th April, 2019, Galway County Council made 2 important points:

• Any Proposals involving HGV Traffic through the town centre will be highly problematic.
• All issues highlighted in the FI (Further information) Request Issued under 18/502 should be addressed in full

Basically on the first application there was  a lot of information missing, so Galway County Council issued an RFI, that contained many requests including the following:

• “The applicant is required to submit a revised EIAR to include an assessment and evaluation of the feedstock to serve the proposed development, which should include the type and locations of all the feedstock sources to supply the proposed biogas plant.”
• “Please submit the locations of all feedstock sources to serve the proposed development and highlight the likely haul routes to be used to and from the development based on realistic travel times.”
• “The likely haul routes should be broken down in the percentages, in order to obtain a clear understanding of the traffic implications of the proposed developments on Gort town.”

The applicant has covered Traffic Assessments in their EIAR but not completely.

Traffic Concerns

The proposed Biogas plant will require 250,000 Tonnes of material to be managed per year.  90,000 Tonnes of input (Feedstock) , 150,000 Tonnes of Digestate (fertiliser) and 5,000-10,000 tonnes of C02/Methane.  This simple diagram shows the process.

All of this material will need to pass through Junction 16, (Glenbrack Roundabout) in Gort as it’s the only exit/entry point allowed. As this is also a motorway exit/entry point there are as many concerns about this, as there are about routing traffic through Gort.

Errors and Inconsistencies

When looking at traffic numbers there are 2 tables in the EIAR document that state different traffic rates – no idea which one they deem is correct so this doesn’t exactly fill us with confidence.

No Seasonal Variations

The traffic assessments give a daily average for the year e.g.

• delivering feedstock (e.g. silage)  10 vehicles/day .. Peaking to 11!
• Collecting digestate ( 11 vehicles/day)

But this doesn’t take into account the seasonal nature of the feedstock or digestate.

Feedstock Delivery

The EIAR emphatically states that “no feedstock deliveries will be made using tractor hauled slurry type tankers” – that however, only applies to slurry – not to silage, so we assume, like most Biogas plants, that it will be tractor and trailer for delivery of silage. We also assume that delivery will be somewhere between 12 and 20 tonnes so an average of 16 tonnes per load. For silage, 54,000 tonnes will have a specific peak wndow, usually May-Sept of around 4 months.

Note : The EIAR also doesn’t answer Galway County Council’s original request for more information on feedstock suppliers, routes.

Digestate Collection

150,000 tones of digestate are predicted to be collected from the Biogas plant. We are assuming that the collection will be done by Tractor with Slurry tanker (see image below)

In the applicant’s EIAR they state:

“In terms of storage capacity, the volume of storage should be guided and sufficiently sized to cater for digestate production between the period mid-October to mid-January (approximately 20 weeks depending on location within the  country and weather conditions).”

So from Mid-January, there are 32 weeks in which to  collect and deliver 150,000 tons of digestate to farms in the vicinity.

150,000 tons in 32 weeks is an average of 34 x 20 tonne Tractor Trailer loads a day so again we could imagine a peak of 3-4 times this and 100 tractors per day would not be unreasonable for a few weeks during peak collection. (Jan/Feb) This contrasts starkly with their proposed 17 vehicles per day.

Ambiguity on Routing traffic through Gort Town

This is the main blind-spot that the biogas developers have.  They have an inability to conceive traffic going through Gort Town.

“TRSA have been informed that hauliers making deliveries related to the proposed development will be contracted to enter the site from the south via the M18 motorway junction 16 to the north of Gort, and via the R458 regional road from the motorway junction to the site access. TTRSA have also been informed that no feedstock deliveries will be made using tractor hauled slurry type tankers and that no feedstock deliveries will be routed through Gort town centre.”

Did you see the blind-spot? Even though Galway County Council have highlighted to the developers that trafffic through Gort would be a major consideration regarding planning – they have completed ignored the 150,000 tonnes of digestate that need to be collected from the site.

Conflict at Glenbrack Roundabout (Junction 16)

It was the key item highlighted in the pre-planning meeting – concern over traffic through Gort town centre and traffic at Junction 16/Glenbrack roundabout.

This roundabout would be used by every vehicle going to/coming from the factory so

• 100 tractors carrying digestate +
• 80 tractors + trailers carrying silage
• 20 tankers carrying slurry
• 4 tankers for Methane +
• 4 Tankers for C0₂ +

These are not unreasonable numbers during a few peak weeks. All of these will pass the Glenbrack roundabout twice.   Over a 12 hour period – this would be an average of a Biogas-related vehicle every 1 minute 43 seconds at Glenbrack Roundabout spread evenly throughout the day.. Which won’t happen that smoothly of course. 

Feeding the Biogas Beast

The biogas plant will be an unpredictable beast to feed and to dispose of its digestate.   There will be peaks in demand for feedstock and digestate but the proposers EIAR is not really considering peak. The Biogas developers have a blind-spot regarding offering any consideration on digestate disposal – It’s like they don’t want to be in any way responsible for its disposal and have offered no insight into how the 150,000 tonnes will be distributed .

Galway County Council have been very clear in highlighting traffic concerns and requested some key data to make proper traffic assessments.   The Biogas Developers (and Halston (https://halston.ie/portfolio/biogas/) have turned a blind-eye on the request – so ..from our point of view, the refusal is well justified.

Recap summary :

• There are inconsistencies in the PCU numbers in Traffic Analysis
• The EIAR fails to provide the detail of information previously requested by Galway County Council
• The EIAR fails to consider seasonal demands of both feedstock and digestate
• The EIAR does not provide any analysis of traffic through Gort Town Centre which will be likely during digestate disposal to lands in vicinity of biogas plant
• The EIAR does not prohibit tractor-based haulage of feedstock (Silage Trailer) and digestate (slurry tanker) and these are common modes of haulage for other biogas plants
• Based on seasonal variation and smaller loading profiles, it is not unreasonable to assume that there could be over 200 vehicles/day visiting the Biogas plant
• The applicatns EIAR does not address traffic concerns adequately and is a reaonsable grounds for refusal of permission