Comment for planning application SCC/0045/23SE

9 Rutherford Place, Withersfield, Haverhill, Suffolk, CB9 7SY

Dear Mr Rutter, I am strongly opposed and object to the planning application made by Acorn Bioenergy/SLR to build an Anaerobic Digestion plant on land at Spring Grove Farm. Without a shadow of doubt in my mind, this location is completely and utterly wrong for such a facility for the following reasons: 1. It is far too close to dense residential areas (less than 600m) and businesses who will be largely impacted by the odour. Jaynic's independent Odour Assessment proves these buildings would be impacted despite Acorn/SLR saying they would not. Multiple examples can be found where AD operators have been fined for not managing odour appropriately. 2. The site is prone to flooding in and around - the risk of displacement of water and pollution into the Stour Brook and watercourses is too high. The flood park is already at maximum capacity so an additional strain would tip it over the edge, literally. 3. This area of land is not designated in the local plan for industrial development in the Haverhill Vision 2031. This area is zoned for improvement in terms of enhancing the green corridor and approach to Haverhill - not putting an industrial scale eyesore at the gateway. 4. Thurlow Estate's current farming practices show no agricultural demonstrable need to qualify for the presence of an AD plant nearby, Acorn would need to take feedstock from elsewhere anyway. 5. Additional HGV traffic movements in and out of the site on an already stretched, high casualty route (A1307) - HGVs entering and exiting at low speed on to a fast road is asking for accidents. According to their ES Planning Statement they say for 10 months of the year that there will be 50-58 HGV/Tractor movements per day but in peak harvest for 2 months that will increase to 148 HGV/Tractor movements per day. Either time of year, that is a huge number straining the network of surrounding routes. They have not specified which roads these movements would occur on - another gap in detail to make a proper assessment of impact. They also note that they will be using the new by-pass road currently under construction! 6. Safety concerns in terms of air pollution and risk of methane leakage, explosions (as demonstrated via various examples, recently in Oxfordshire) especially with the storage of highly flammable gas (Biomethane and also bought in and stored Liquid Natural Gas (LNG) as a supply connection is not available to the site), light pollution etc. Their plans do not include detail on CCTV being installed (just it "may be needed" in Section 4.4.3 Fencing of the ES Planning Statement) nor how the remote monitoring would work. 7. One of the biggest gaps in information, is they have not provided adequate nor any additional information on what alternative sites they have looked at and assessed as part of their Environmental Impact Assessment. There is NO evidence of them undertaking a wider search or review of other sites beyond those initially scoped. Therefore, they have not followed the Environmental Impact Assessment Survey Guidance 18 regulation part (d) on assessing alternative sites. In their ES Planning Statement Section 3.1 Site Selection - both of the sites they mention (near to former RAF Wratting Common airfield and one north of Silver Street - all owned by Thurlow Estate) aren't too far away from the Jelly Warehouse located along Skippers Lane, West Wickham. By nature of this storage facility, they have HGVs coming and going every day via approved routes onto the A-roads which do not go via Withersfield. As part of this guidance, they should have provided a detailed section on other alternative sites but it is clear they have not assessed any additional ones beyond what they originally scoped and have not followed guidance. 8. From reviewing Acorn's application documents, there are too many question marks over the validity and quality of their application to satisfy any form of my support. I have been following the application ever since they added their scoping application, attended their exhibitions, reviewed the information they have provided and now critiqued their current application and I am consistently concerned by: 1. Large gaps in precise and specific information given, often ambiguous or only meeting the absolute minimum criteria of standards. 2. Errors, typos, incorrect references littering their documents through inadequate quality checking e.g. it is clear they copy and paste from other applications in other locations when they reference a road in Northamptonshire (A43 is referenced on their Environmental Survey Planning Statement, Section 3.2.1.1 Design Principles - Embedded Mitigation). 3. Lack of response to questions when contacted directly or not able to respond directly in person with accurate information - no evidence of actually wanting to engage meaningfully, just doing things to tick some boxes 4. Lacklustre and unpolished presentations given at various forums including the Haverhill Town Council. All of these points put together are not filling me with confidence over their actual abilities to provide a well-built, well managed and safe facility. And of course, they do not have any proven experience to date because they do not have any active facilities. The fact still remains, Spring Grove Farm and any area around this vicinity is not appropriate for this facility. Best wishes