The Planning Authority,
Kildare County Council,
Naas, County Kildare,
1 February 2017
Applicant: Bord na Mona
Proposal: 3,380m2 horticultural facility and ancillary structures
Dear Sir or Madam;
We refer to the application form by the developer and note that they state that no Environmental Impact Statement is required’. [Page 6]
We note the decision of An Bord Pleanala upheld by the High Court in relation to Edenderry Power Plant whereby the source of the fuel was required to be considered as part of the application for the continuation of the plant [PL 19.245295].
Notwithstanding this judgment against the current applicant, the Environmental Impact Assessment Report is concerned only with the processing facility and offers no assessment of the extraction of peat necessary for this planning application although it is admitted in the ‘Characteristics of the proposed development’ (Appendix E, 3.2) that the material for the proposal will be sourced from ‘Moulds Bog/Bog of Allen’.
This EIA Report states that the materials would be extracted in the absence of the proposed development. ‘Market demand is the driver for the extraction of these materials, not the proposed development.’ It is difficult to see that the extraction on the scale proposed would happen if this facility was not constructed.
However, the question; ‘Would any contribution of the above factors be considered likely to have significant effects on the environment?’ meets the reply ‘It is not considered that the combination of the above factors could result in significant effects on the environment.’
Similarly, the claim that the peat would be extracted anyway is advanced again under Appropriate Assessment, which confirm the extraction of 215,000m3 per year from a resource of 6,612,327.6m3.
Further, the Summary of Potential Environmental Impacts of the Development of a Horticultural processing facility Allen Bog in the Screening for Appropriate Assessment [3.3.3]. does not address the impact of the extraction of peat and its conclusion considers only the impact of the construction of the processing facility.
Bord na Mona prepared and submitted an EIS and AA in relation to the extraction of peat for the Edenderry power plant in June 2016, a ’fall back’ application in view of the likelihood of the High Court striking down the original application that contained no such assessments. This duly took place.
We would suggest to the Planning authority that in view of the planning history of the Edenderry Power Plant, the Local Authority has no choice but to refuse this application until the extraction of the peat required to supply this facility is addressed.
We attach the €20 participation fee.