Introduction
CALNI have submitted a succession of general papers to the Planning Service in response to the Rose Energy application. Our first paper, “Protecting the Future” was issued on 24th September, 2008. It is a weighty document with over a hundred pages. In the months that followed, Rose made some significant changes to their application, submitting new documents in the process. We responded to these with “Protecting the Future - An Addendum” on 20th August, 2009. The submission of CALNI documents concluded with the submission of “Protecting the Future - Securing the Present”. This summary document was lodged with the Planners on 19th October. |
PTF Summary Rose Energy (the company) has submitted thousands of pages in support of its application (S/2008/0630F) to build and operate an incinerator on a site near to Ulster Farm By Products (UFBP) on the Ballyvannon Road, Glenavy. Yet in all these pages it has failed to address, let alone answer, the fundamental criticisms we made of its application in our report, Protecting the Future (PTF), submitted to Planning Service in September 2008. The company has simply continued to repeat the points made in its initial submission, hoping that repetition rather than reasoned argument will convince people of the strength of its case.
Hence, as the public consultation on the company’s application now draws to a close, this short note focuses attention on the basic weaknesses in the company’s case by briefly restating the key criticisms that we and others have made of its application.
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PTF 2008
This paper is essential reading for anyone who wants to understand the issues surrounding Rose Energy’s planning application for an incinerator on a site near Glenavy that overlooks Lough Neagh. By covering the legal, planning, technological, and site-selection issues in considerable detail, it provides a robust reply to the company’s application. But it also examines the economic and commercial aspects of the proposed development and analyses the company’s claim that the project is in the “public interest”.
I found the section of the paper on the “public interest” particularly pertinent. Since the debate on Rose Energy’s planning application began many months ago, few – not even the company – have claimed that incineration is an ideal solution to the waste-disposal problem faced by the poultry industry. Again and again, however, the company has argued that a quick solution is more important than a thorough and transparent investigation of the issues, and that the government must act fast, ignore established procedures, and approve the proposed development immediately in the “public interest”. But the paper demonstrates that the company’s use of the “public interest” is a flag of convenience behind which it hides its own self-interest to make a profit and ignores the interests of virtually everyone else: poultry farmers; beef and dairy farmers; those who reside, work, or pursue leisure activities in Glenavy-Crumlin and, more generally, in the area surrounding Lough Neagh; and the government and tax payers of Northern Ireland. Hence there is no basis whatsoever to circumvent due process or cast aside the score of common-sense, economic, and planning reasons why the proposed development is completely inappropriate.
In closing, I would like to reiterate CALNI’s fundamental objection to Rose Energy’s planning application. Our position is that incineration is not an appropriate solution to the problem of poultry litter – it merely replaces one form of pollution with another – and that, even if it were, the proposed site is one of the last places in Northern Ireland that such a facility should be located. Hence we ask the Department to reject the company’s planning application; failing that, the Department to establish a Public Inquiry; the Public Inquiry to reject the company’s planning application; and the Department to confirm the Public Inquiry’s rejection.
Danny Moore
President, CALNI
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PTF 2009
In September 2008 we submitted a report, Protecting the Future, to Planning Service in response to the consultation being undertaken on the application (S/2008/0630F) submitted in June 2008 by Rose Energy Limited (the company) for planning permission to build and operate an incinerator on a site near to Ulster Farm By Products (UFBP) on the Ballyvannon Road, Glenavy. The present paper is an addendum to our initial report.
In February 2009, Planning Service requested further information from the company on a number of matters contained in its initial application. Following this request, the company made a major change to one aspect of its application. It had initially proposed that the primary source of water for steam generation and cooling would be the aquifers below the site. But, as local residents had suggested on the basis of their own calculations as well as studies done in the area in the 1990s,1 the volume of water from these aquifers was insufficient. Hence the company is now proposing to draw water directly from Lough Neagh – a SPA, ASSI, and Ramsar site – and pipe it to the plant.
Faced with this new proposal, Planning Service requested that the company submit not only an Addendum to its initial Planning Application and Environmental Statement (ES) but also an Environmental Statement that would deal with the water abstraction facility and pipeline from Lough Neagh. The company submitted this document to Planning Service in June 2009.2 Much of the document is highly repetitive of the company’s initial submission and fails even to address, let alone answer, the criticisms we made of it in Protecting the Future (PTF). Little would be gained, however, by repeating all these criticisms here. Instead, we simply ask Planning Service, in considering the company’s ES:AR, to bear in mind the arguments we advanced in PTF together with the findings of the further expert studies that CALNI has commissioned on the following matters dealt with in our initial report: planning statements and policies; ecology; visual impact and massing, scale and design of buildings; roads and traffic; alternative technologies; and alternative sites. Planning Service has already received some of these studies,3 and the rest will follow shortly.
In this paper, therefore, we restrict ourselves to commenting on three topics:
- The advantages of combined heat and power plants compared with power-only plants.
- The volume and quality of poultry litter available in Northern Ireland.
- BMAP Policy COU 7
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