Article 14 Reply - Attachment 2

Transcription

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Attachment 2
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Copy of – Further Information Request from
Planning Authority, Further Information Reply,
Decision to Grant Planning Permission,
Final Grant of Planning and the Planners Report in
respect of Planning Application 12/234
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EPA Export 01-07-2013:23:45:33
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Michael Dalton
Tankerstown Pig & Farm Enterprises
Tankerstown
Bansha
Co Tipperary
Tel 052 54152
Planning Department
South Tipperary County Council
County Hall
Clonmel
RE Further Information Clarification : Planning Ref 12/234 Michael Dalton, Tankerstown Pig & Farm
Enterprises.
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Dear Sir
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I attach here our further information submission in relation to the above mentioned Planning Application.
The submission Includes the following
Reference
Description
Submission Further Information Clarification Reply
Appendix 1 Drawings
107 Details of Weigh Bridge No 29-30
108 Details of Silage Apron
Qty
4
(A3) 1:200
4
(A3) 1:200
4
(A3) 1:100
4
(A3) 1:100
4
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110 Details of Tanks
Appendix 2
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109 Details of Intake
Scale
Paper Notice & Site Notice
4
Off Site Housing Agreement
4
Water Analysis
4
Appendix 3
Appendix 4
I trust the submissions included here are sufficient to meet the requirements of the Planning Authority
Yours Sincerely
Michael Dalton
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Further Information Clarification : Planning Ref 12/234
Michael Dalton, Tankerstown Pig & Farm Enterprises
1.
The response to further information item 1 includes a site layout plan identifying in
red the structures for retention permission as significant further information. These
are buildings /structures labelled no.’s 6, 13, 21, 9, 15, 16, 24, 25, 26, 28, 29, 30 and
31.
The further information submission does not include for plan/elevation drawings of
all structures/buildings for which retention permission is now sought.
In addition the public notices of further information does not includes for all
buildings/structures for which retention permission is sought.
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Please regularise.
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Copies of the site Notice and Paper Notice amended are included in Appendix 2
Copies of structures Drawings as per the schedule below are attached in Appendix 1
107 Details of Weigh Bridge No 29-30
(A3) 1:200
4
108 Details of Silage Apron
(A3) 1:200
4
(A3) 1:100
4
(A3) 1:100
4
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110 Details of Tanks
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109 Details of Intake
2.
Further information item 2 requested that a chronology of development undertaken
on the site post 1960 be submitted together with details of piggery type, stock
numbers and capacity relative to the chronology of development.
The details received show that the pig enterprise had approx 700 no. sows in an
integrated unit from the mid 1970’s and that the number of sows (farrowing sow
places and dry sow places) in the enterprise prior to 1990 was 700 approx with 150
no. served gilt places.
The Decision of the European Court Case C5985-10 changed the definition of a sow to
include served gilts, which the further information identifies as 25% maximum of the
sow herd. This gives rise to an increase of places for sows by 175.
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The Planning Authority advise that this increase in ‘places for sows’ may give rise to
the requirement for Environmental Impact Assessment or EIA Screening.
The current standards for EIA for pig production facilities is set out under Schedule 5
of the 2001 Planning and Development Regulations, as amended. Item no. 1(e)(ii) of
Part 2 of the fifth schedule of these regulations refers to:
Installations for intensive rearing of pigs not included in Part 1 of this schedule,
which would have more than 2000 places for production pigs (over 30kg) in a
finishing unit, more than 400 places for sows in a breeding unit or more than 200
places for sows in an integrated unit.
Class 13 of the Planning and Development Regulations 2001, as amended, set out EIA
thresholds for changes or extension to developments as follows. This threshold came
into force in 1999 and is as follows:
(a) Any change or extension of development which would—
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(i) result in the development being of a class listed in Part I or
paragraphs 1 to 12 of Part II of this Schedule, and
(ii) result in an increase in size greater than—
—25%, or
—an amount equal to 50% of the appropriate threshold,
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whichever is the greater.
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In the subject case and on the basis of the details provided the Planning Authority
advise that the places for sows numbers has increased by 175 places, from 700 in
place pre 1990. This represents an increase of 25% of places for sows and exceeds
50% of the appropriate threshold for the intensive rearing of pigs, which requires
EIA for more than 200 sows in an integrated unit.
The herd size sow numbers have been managed on the farm facility since the late 1970’s as
described above the area per animal provided was less than in recent times. The additional
building since has been in the main to accommodate larger space per animal housed and to
accommodate greater performance and larger size stock, resulting from improvements in
genetics and animal husbandry management.
By 1990 the stock numbers accommodated on the farm were
PIG TYPE
Farrowing Sow Places
203
Dry Sows Places
500
Boars Places
36
Served Gilt Places
150
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M Gilts Places
Weaner Places
Fattener Places
0
2269
5631
The stock numbers and by virtue the impacts from the development has been installed and
operational by the end of the 1970’s, the additional structures constructed on the farm complex
since then were to accommodate improvements of animal husbandry practice and to provide
additional space for finishing pigs to larger weights as market demand changed.
The newer structures on the farm identified on the table at Point 2 above were to provide
additional space per stock particularly on fattening where the market demanded larger weights
for fat pigs as well as increased production from improved genetics.
Definition of a Sow
Definition of what is a “Sow” has been an adult female swine; the definition of a sow for the
purpose of animal numbers for licence thresholds has been as An Adult female swine having
farrowed her first litter. This has defined the number of pig places on this integrated unit, also
the number breeding stock replacement followers (Gilts) maintained as a general rule 15% to
25% of the sow herd is replaced on a year on year basis.
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Court Ruling
In the Decision of the European Court Case C-585/10, the definition of Sow has encompassed
served Gilts to the defined sow numbers. The result of this decision has elevated the theoretical
sow numbers on a facility which would bring a previously sub-threshold integrated (<200 Sows)
unit over the EIA threshold even though the impacts generated from the farm would remain be
the same. In the case of the Applicants farm the impact from the development was set in the
late 1970s.
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In order to satisfy the requirements of the above referenced case the applicant has entered into
an agreement to maintain the Gilts for the unit off site until they enter the farrowing house. It is
intended to maintain this arrangement until the IPPC licence and separate expansion Planning
permission has been processed. Copy of the agreement is attached in appendix 3
Conclusion
We must point out that there have not been any incidents or complaints from the operation of
the facility in the intervening years to warrant investigation by the Local Authority. There has not
been any increase in sow numbers or additional impact from the to warrant an EIA for the
following reasons
• The installation size of 700 sow integrated unit has been operational since the 1970’s,
with no increase in sow numbers since. The impacts from the development have been
relatively similar since then.
•
The change in Definition of a sow to incorporate Served Gilts does not change the
overall impacts from the installation in that the gilts are already managed on the facility.
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3.
The Planning Authority note that waters from the site drain to the Aherlow
River channel. You are requested to clarify whether the surface water has
been tested prior to its off site discharge. If so please provide details of the test
results, when same was undertaken and water quality parameters tested
Copy of the Water analysis taken from Monitoring Point is included in Appendix 4
The Planning Authority notes that notices of significant further information
were included with the further information submission. The submitted
newspaper notices does not satisfy the requirements of Article 35 (1) (a) of
the Planning & Development Regulations 2001, as amended.
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You are required to accompany any future further information response with
a revised newspaper notice and site notice of further information that satisfy
the requirements of Article 35 (1) (a) of the Planning & Development
Regulations 2001, as amended. Please note that the site notice of further
information should also be fixed to site to which this application relates, as
required under Article 35 (1) of the Planning & Development Regulations
2001, as amended.
Copy of the Newspaper Notice and Site Notice is attached in Appendix 2
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4.
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Appendix 1
Drawings
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Appendix 2
Public Notices
EPA Export 01-07-2013:23:45:34
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THEINTONCATING
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h Receivership)
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by Notice is hereby given that on (Ireland) Lirnited having its Permission to retain the
THEINTOKCATING
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the l5th day of October,2012, registeredaddressat Georges Nofth Weriirer House Exlen(b) Retention
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BAANSIAMCT]ISINE
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in the course of a
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Farrowing
trade, business or
Take notice tlat Baan Siam made between Cronan Nagle February,2005 (the "Mortgage House; with all associated
ILECTRONICS Courses City
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Cuisine Limited trading as Consffuction Limited
& Guilds.Tel 1850 759 759
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applicafion znd Proposed
ldms, serviced& timing.belt Dublin 18, intends to apply to Charleston Road, Ranelagh,
Dublin 2, to be Receivers
and Develooment will
not
fitted, tared 04-13, DOE lhe CircuitCourtsittingat Circuit
Dublin 6 (the "Company") Receivers& Managersover the increase the number of
05-15, May consider trade
Court 28, Four Courls, Inns and Allied Irish Banla, p.l.c. assets
comprised
in aadsecured animals on site) at Tankerin, €10,500. 087-7103474
stown, B'ansha,Co. TipperQuay,Dublin 7, at l0ani in the haYing ils registered office at by theMortgageandCharge.
arv have been fumished to
forenoonon Thursday,the 15th Bankcentre,Ballsbridge,Dublin Dated:15Octobef,
2012
the planning authority. This
dayof November,
2012,or al tle 4 (fte "Bank"),whichDebenture
A&TGOODBODYinformation includes the
first opportunitythereafterfor a is an acquiredBankAssetwithin
Intemationallinalcial modification the site boundCertificateentidingand enabling the meaningof the NAMAAct,
rostanna do Mhriinteoiri
Serrices
Centre ary, dre incorporation of
theApplicantto receivea Special appointed Declan Taite and
',trisc 2073: 23ft Mtuta - 6i
storm water attenuation
NorthWallQuay,Dublin I
GREAT' Island Car Rentals Restaurant
Licence
in
respect
ol
system, retention of Finishnbrein. '16 foftintaisi ag
Anne O'Dwyer of RSM larrell
Ph.021-481160924hrs
the restauranlpremisesof the Grant Spaxl$,MolyneuxHouse,
ing/stock Houses 6, 24&25,
)ol6isti Chorca Dhuibhne,
Gilt House 15, Dry Sow
lo Mhriinteoiri Bunscoile &
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dednscoile. Cur amach ag
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andsitu^teat Centrrl StatutoryReceiYers
of the assets
Boiler House ?1, Pump
nriinteoiri ar Churaclam na
Park, Block I Leopardstown, of the Companychargedby the
lunscoile agus ar Theagasc
H ouse 1 3, tank s 28,31,
Dublin 18, CountyDublin,which Debenture.
ra Gaeilge inmhianaithe. Ni
ROSCOMMON COUNTY weighbridge29, 30 & intake
premises is Dated:15thOctober,
said
restaurant
2012
The
Development
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COUNCIL: Joseph and Mary 9.
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pose of an activity requiring
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hearing of fte Applicationand 91 SouthMall,Cork
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and Control Licence.
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planning reference no. That the Significant Furlher
Information
/ Revised Plans
06/|004 to construct one
Datedthis 16th day of October,
may be inspected, or purdwellinghouse
and
sewerz0 t2
age system at Doonard chased at a fee not exceedBISHOPSTO\IT{ Residential Present
whenthe
COMPANIES
AC"IS
More, Strokestown, Co. ing the reasonable cost of
Shop Premises with Deli. commonsealof
(courw)
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Good Parkins. Irish &
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NONCEOFAPPOINTMENT
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may
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during its public opening
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sonable cost of making a observation in relation to
IIMITED (In Receivership)
the further information/
Ame Marie 087 6638560
Signed:SUMPORN
IANCASTERNotice is hereby giYenthat on copy, at the offices of the
Planning Authorif during its revised pl'ans may be made
(Dtector)
in writing to the Planning
10 October,2012, UisterBank
Signed:COMPION
AYLMER (Ireland) timited having its public opening hours and Authority, on payment of the
submissions or observaSolicitorsfor theApplicant registered address at Georges
tions in relation to the prescribed fee, not later
Company
(the
"Bank"),
application can be made to than 2 weeks from the date
Dublin
2
Quay,
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PembrokeHouse
the authority in writing, on of receipt of site notice and
powers
under
conferred
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top
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delivered
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payment of the prescribed newspaper notice by the
30
(i)
it
by
charge
dared
25
or
collected.
Pouladuff
period of 5 PlanningAuthori{.
Dublin 2
GN required
Norwood DismantlersCork Ltd.
(ii)
February, 1999;
Account fee, within a
weela beginning on the date
Grange Nursing Home P h . 0 2 l - 4 3tt0 5 l
TOWHOMIT MAYCONCERN Chargedated25
Jnnaxy,2012; of receipt by the authority of
apprcx- 2 nights per week.
and (iii) Mortgageand Charge the application.
Must be flexible. Reoliesto
dated 3 April, 2012; each of.
norwoodgmnge@
gmaiicom
. ANCIIUIRTCHUARDA which is betweenthe Bank and
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LaremountHoldingsLimited of
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IndustrialPark,
CoudNo.28 SnugboroughRoad, Dublin 15
FOR sale big square bales of Dublin
(the "Security Documents"),
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TI]EIICENSING
ACTS
DavidO'Connor
of BDOSimpson
1833ta 2012
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THEINTONC{]NGUQUOR
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& Managers over the assets
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AC! 2000,Section
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Security
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successfully treat smoking,
Provisions)
ACT,1961
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slimming, an\iety, stress,
Dated:15October2012
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- A&LGOODBODY
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EPA Export 01-07-2013:23:45:34
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South Tipperary County Council, Áras an Chontae, Clonmel.
Tel.: 052-6134646
Site Notice of Further Information/
Revised Plans
NAME OF APPLICANT1: ……Michael Dalton ……………………………………….……….
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Ref. No. of Planning Application2 …12/234 ……...
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The Development Applied for consisted of3
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PERMISSION FOR RETENTION off the following developments(:a ) Retention Permission to retain the North Weaner House Extension and (b)
Retention Permission to Retain the South Weaner House Extension- constructed on site (c) Permission to construct new Dry Sow House (d)
Permission to construct new extension to Farrowing House; with all associated site works; In order to comply with animal welfare regulations- as
per S.l. No. 48 of 2003. (Note: This application and Proposed Development will not increase the number of animals on site) Co.Tipperary has been
submitted. This information includes the incorporation of storm water attenuation system, retention of Finishing/stock Houses 6, 24&25, Gilt
House15, Dry Sow House16, Silage Apron 26, Boiler House 21, Pump House 13 , tanks 28,31, weighbridge29, 30 & intake 9..
AT: ________ Tankerstown
Bansha Co.Tipperary ____________________________________________________________
Signed4: …
Date of erection of site notice5: …16 October 2012
Significant Further Information/Revised Plans6 has/have6 been furnished to the Planning Authority in respect of this
proposed development, and is/are6 available for inspection or purchase at the offices of the Authority (9.00am – 1.00pm
and 2.00pm – 5.00pm – Mon. – Fri. excluding public holidays). A submission or observation in relation to the application
may be made in writing to the Planning Authority within a period of two weeks from the date of receipt of site
notice/newspaper. The Planning Authority may grant permission subject to or without conditions, or may refuse to grant
permission.
EPA Export 01-07-2013:23:45:34
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Appendix 3
Confirmation on Gilts off Site
EPA Export 01-07-2013:23:45:34
Main St
Ballyporeen,
Co Tipperary,
Tel 052 7467185
Fax 052 7467185
E-mail info@nrge.ie
15th October 2012
Planning Department
County Hall
Clonmel
RE
Further Information Clarification : Planning Ref 12/234 Michael Dalton,
Tankerstown Pig & Farm Enterprises.
I confirm Michael Dalton has made arrangements to house up to 150 gilts in the slatted shed
located on the family holding at Barnlough, Bansha located 300m from the development site.
to
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The arrangement to house gilts will remain in place until the Planning Permissions and IPPC
licences are in place.
We trust this submission satisfies the Planning Authority
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en
Yours Sincerely
Michael McEniry
NRGE LTD
Nutrient Recovery to Generate Electricity Ltd. is registered at Mooresfort, Lattin, Co.Tipperary. Company Reg. No 392619
Directors M. Sweeney, N. Sweeney, E. Mc Eniry, M. McEniry Secretary.
EPA Export 01-07-2013:23:45:34
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Appendix 4
Water Analysis
EPA Export 01-07-2013:23:45:34
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EPA Export 01-07-2013:23:45:34
Michael Dalton
Tankerstown Pig & Farm Enterprises
Tankerstown
Bansha
Co Tipperary
Tel 052 54152
Planning Department
County Hall
Clonmel
RE Unsolicited Further Information: Planning Ref 12/234
Michael Dalton, Tankerstown Pig & Farm Enterprises.
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Dear Sir
to
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I attach here unsolicited further information in relation to the above mentioned Planning Application.
The submission Include an agreement with Denis Moran to house up to 150 gilts on his farm at Ballycarron,
Bansha. This allows the gilts to be kept in more appropriate housing than the slatted cattle shed.
I trust the submissions included here are sufficient to meet the requirements of the Planning Authority
Co
Michael Dalton
ns
en
Yours Sincerely
EPA Export 01-07-2013:23:45:34
EPA Export 01-07-2013:23:45:34
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SOUTH TIPPERARY COUNTY COUNCIL
PLANNING AND DEVELOPMENT ACTS, 2000 TO 2010
PLANNING AND DEVELOPMENT REGULATIONS 2001 - 2012
NOTIFICATION OF DECISION TO GRANT IN ACCORDANCE WITH
SECTION 34 OF THE 2000 ACT.
Michael Dalton
c/o Eamonn M Hughes
Tir na nOg
Grangefertagh
Johnstown
Co Kilkenny
Ref No. 12/234
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se
.
FURTHER INFO RECD 16/10/2012
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APPLICATION RECEIPT DATE: 22/06/2012
Having regard to:
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the nature and extent of the proposed development;
the intended use of the proposed development,
the policies of the County Development Plan 2009 and
the pattern of development in the area,
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it is considered that, subject to compliance with the conditions set out in the attached Schedule,
the proposed development;
would not seriously injure the amenities of the area or of property in the vicinity;
would not be prejudicial to public health;
would be acceptable in terms of traffic safety and convenience;
would not impact on a Natura 2000 site.
would, therefore, be in accordance with the proper planning and sustainable development of the area.
Page 1/2
EPA Export 01-07-2013:23:45:34
In pursuance of the powers conferred upon it by the above-mentioned Acts, South Tipperary County
Council has by Order dated _____ November 2012 decided to GRANT PERMISSION AND
PERMISSION FOR RETENTION to the above named for development of land, as follows:the following developments: (a) Retention Permission to retain the North Weaner House
Extension and (b) Retention Permission to retain the South Weaner House Extension constructed on site (c) Permission to construct new Dry Sow House (d) Permission to construct
new extension to Farrowing House: with all associated site works, in order to comply with
animal welfare regulations - as per S.I. No. 48 of 2003. These developments are for the purpose
of an activity in relation to which an integrated pollution control licence is required (Note: This
application and Proposed development will not increase the number of animals on site)
At: Tankerstown Bansha Co. Tipperary
Subject to the 13 conditions and reasons therefore as set out in the schedule attached.
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If there is no appeal against the said decision, a GRANT in accordance with the decision will be issued
after the expiration of the period within which an appeal may be made to An Bord Pleanala (see appeal
details overleaf).
IT SHOULD BE NOTED THAT UNTIL A GRANT OF PERMISSION OR PERMISSION
CONSEQUENT ON THE GRANT OF AN OUTLINE PERMISSION HAS BEEN ISSUED, THE
DEVELOPMENT OR RETENTION IN QUESTION IS NOT AUTHORISED.
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Signed on behalf of South
Tipperary County Council ………………………………………..
County Secretary.
Dated:………………November 2012
Page 2/2
EPA Export 01-07-2013:23:45:34
Planning & Development Acts 2000 to 2010
Ref No. In Planning Ref:
12/234
Page 1/4
Schedule referred to in Order No. ___________________________
SCHEDULE
1.
Save where modified by the following conditions, the proposed development shall be
retained, carried out and completed in accordance with the drawings and documentation
submitted with the planning application on the 22nd June 2012, as amended by revised plans
and particulars received on the 26th September 2012 and the 16th October 2012 as further
information.
Reason: In the interest of proper planning and sustainable development.
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se
.
Within 12 weeks of the receipt of this notice, unless otherwise agreed with the Planning
Authority, the applicant/developer shall pay to the Planning Authority a development
contribution in the sum of €10,506.94 in respect of the provision of improved road
infrastructure.
(i)
The amount of the development contribution shall be in accordance with the
following class as detailed in the current South Tipperary Development
Contribution Scheme:
Area sq. m
Total
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Rate 2012
Co
n
Class 6
Agriculture- in excess
of 600 sq m.
Roads
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2.
€6.40 p er m2
1,641.71 m2
€10,506.94
€10,506.94
Reason: As a contribution towards the cost of the provision of improved road
infrastructure in accordance with the South Tipperary Development Contribution
Scheme 2011-2015 which was adopted, pursuant to Section 48 of the Planning and
Development Act, 2000 by resolution of South Tipperary County Council, dated 7
February 2011. Such improvements will facilitate this development.
3.
Within 12 weeks of the receipt of this notice, unless otherwise agreed with the Planning
Authority, a revised set of elevation drawings to a scale of 1:200 shall be provided for the asconstructed buildings/structures labelled as buildings/structure no.’s 15, 16, 24, 25, 28 and
31.
4.
a) Within 12 weeks of the receipt of this notice, unless otherwise agreed with the Planning
Authority the applicants shall engage a suitably qualified person to examine the septic tank
system and determine whether same complies with the requirements of the EPA 1999
EPA Export 01-07-2013:23:45:34
12/234
Page 2/4
SCHEDULE
Wastewater Treatment Manuals-Treatment Systems for Small Communities, Business,
Leisure Centres and Hotels. A report describing the results of the investigation shall be
forwarded to the Planning Authority on completion.
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b) Should the existing septic tank effluent disposal system not comply with the requirements
of the EPA 1999 Wastewater Treatment Manuals-Treatment Systems for Small
Communities, Business, Leisure Centres and Hotels. the applicant shall submit proposals, viz
a separate planning application, for the upgrade of the effluent disposal system to EPA 1999
Wastewater Treatment Manuals-Treatment Systems for Small Communities, Business,
Leisure Centres and Hotels requirements. This application shall be made within 4 weeks of
the completion of the investigation report as required under condition no. 4 a), unless
otherwise agreed with the Planning Authority.
Reason: In the interests of environmental protection and public health
a) Uncontaminated surface water runoff from roofs and clean paved areas within the
farmyard shall be collected separately from farmyard wastes (slurry, silage effluent and
contaminated /soiled surface water) and shall be disposed of directly in a sealed system which
shall drain to a proposed surface water attenuation system.
b) The surface water attenuation system shall be installed on site and the necessary pipe work
shall be installed to ensure all uncontaminated surface waters are collected and drain to this
attenuation system prior to discharge to a watercourse. These works shall be undertaken and
completed within 12 weeks of the receipt of this notice unless otherwise agreed with Planning
Authority.
c) No contaminated surface waters, soiled waters, slurry or silage effluent or washings from
the pig farm shall discharge to the surface water system or any watercourse, stream or drain.
Surface water shall not be allowed flow onto the public road or adjoining properties.
d) As and when required by the Planning Authority a sample of waters shall be tested and
results of the test submitted to the Planning Authority. The water sample shall be taken prior
to discharge from the surface water system to the watercourse.
Co
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5.
Reason: In the interest of orderly development and environmental protection.
6.
This permission does not provide for any increase in stocking rate or sow numbers above
existing permitted levels.
Reason: In the interest of clarity and the proper planning and sustainable development
of the area.
EPA Export 01-07-2013:23:45:34
12/234
Page 3/4
SCHEDULE
7.
•
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•
The applicant shall ensure that all farm activities within farmyard are carried out in
accordance with the recommendations set out in SI 378 of 2006, European Communities
(Good Agricultural Practice for Protection of Waters) Regulations, 2006. Storage facilities
shall:
Be designed, sited, constructed, maintained and managed so as to prevent run-off or seepage,
directly in indirectly, into groundwater or surface water of livestock manure, organic
fertiliser, soiled water and effluents from dungsteads, farmyard manure pits or silage pits
Comply with such construction specifications for those facilities as may be approved from
time by time by the Minister for Agriculture and Food.
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Reason: In the interests prevention of environmental pollution and protection of waters
including groundwater.
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8. Farmyard wastes (slurry, silage effluent, milking parlour washings and contaminated surface
water) shall be disposed of by spreading on land in accordance with SI 378 of 2006 European
Communities (Good Agricultural Practice for the Protection of Waters) Regulations, 2006 (or
as amended) and no such spreading shall be carried out on any land that is within 50 metres
of any school, hospital, church or building used for public assembly or within 30 metres of
any private dwelling house (except the landowners own dwelling) save with the consent in
writing of the owner and, as may be appropriate, the occupier or person in charge thereof.
Reason: In the interests of orderly development, public health, the protection of the
amenities of the area and the avoidance of pollution of ground or surface waters in the
area.
9. The transportation of farmyard wastes (slurry, silage effluent, milking parlour washings and
contaminated surface water) via the public road shall be carried out in a sealed and watertight
tanker/container such that no spillage of deleterious matter can occur onto the public road.
Should such a spillage occur the developer shall take all necessary steps to clean same
immediately.
Reason: In the interest of traffic safety and public health.
10. All oxidisable and galvanised surfaces of the proposed pig sow house and extension to the
farrowing house shall be painted a dark green matt colour or other dark colour approved by
the Planning Authority and the surface shall be maintained in a neat, tidy and painted
condition at all times.
Reason: In the interest of visual amenity.
EPA Export 01-07-2013:23:45:34
12/234
Page 4/4
SCHEDULE
se
.
11. All existing hedgerow boundaries to the site shall be maintained and strengthened and all
other site boundaries shall be planted with a mix of deciduous shrubs suitable for hedging and
common to the locality (e.g. holly, hawthorn, blackthorn, ash). A minimum of 20 deciduous
trees of native (not dwarfed) species shall be included in the hedgerow or elsewhere in the
landscaping of the site. Suggested species include ash, silver birch, oak, apple, scots pine and
these shall be in excess of 3.5 metres in height when planted. The trees shall be maintained
indefinitely and replaced if failure occurs. All landscaping shall take place in the first
planting season following occupation of the dwelling. No leylandii cypress trees shall be
permitted on this site or its boundaries.
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Reason: In the interests of visual amenity.
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12 a) Railway Mounds and ditches to be preserved except where written consent of IE has been
sought and received.
b) No liquid shall discharge or escape onto railway property. Any discharges under railway
property will need agreement with IE/CIE.
c) Services to cross railway property must be subject of wayleave with IE/CIE.
d) Works on and adjacent to the railway are required to meet the terms of the Railway Safety
Act 2005.
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Reason: In the interests of proper planning and sustainable development.
13. The applicant shall submit a nutrient management plan by the 1st of January next, and
annually thereafter, a revised Nutrient Management Plan. The NMP shall include the
following minimum information:
• Annual production of manure and the nitrogen and phosphorus content of the manure
• Summary of the farmers receiving manure, if manure is to be exported off the applicants
landholding
• The NMP shall demonstrate that all lands have adequate capacity for recovery of the manure
generated by the facility.
• The NMP shall maintained at the facility, and made available for inspection, if requested.
ng
EPA Export 01-07-2013:23:45:34
PLANNING AND DEVELOPMENT ACTS, 2000 - 2010
COUNTY MANAGER’S ORDER
ORDER NO._____________
Subject: Planning Permission
Ref No. 12/234
WHEREAS by Manager’s Order No.158766 dated the 29th April 2011, William McEvoy,
County Manager for South Tipperary County Council did pursuant to powers conferred on
him by Section 154 of the Local Government Act 2001, delegate unto me certain powers,
functions and duties as set out therein.
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NOW THEREFORE pursuant to the delegation of the said powers, functions and duties
aforesaid, I, Sinead Carr, Director of Services, HEREBY DECIDE, pursuant to the
provisions of the Planning and Development Acts, 2000 to 2010, to GRANT PERMISSION
AND PERMISSION FOR RETENTION as set out hereunder in accordance with the
application received. This PERMISSION AND PERMISSION FOR RETENTION shall be
subject to 13 conditions and reasons specified in the Schedule attached hereto. If there is no
appeal against the said decision, a Grant of PERMISSION AND PERMISSION FOR
RETENTION in accordance with the decision will be issued after the expiration of the period
within which an appeal may be made to An Bord Pleanala
NAME OF APPLICANT:
Michael Dalton
Co
n
se
nt
o
ADDRESS OF APPLICANT:
LOCATION OF DEVELOPMENT:
c/o Eamonn M Hughes
Tir na nOg
Grangefertagh
Johnstown
Co Kilkenny
Tankerstown
Bansha
Co. Tipperary
NATURE OF DEVELOPMENT:
the following developments: (a) Retention
Permission to retain the North Weaner House Extension and (b) Retention Permission
to retain the South Weaner House Extension - constructed on site (c) Permission to
construct new Dry Sow House (d) Permission to construct new extension to Farrowing
House: with all associated site works, in order to comply with animal welfare
regulations - as per S.I. No. 48 of 2003. These developments are for the purpose of an
activity in relation to which an integrated pollution control licence is required (Note:
This application and Proposed development will not increase the number of animals on
site)
Signed:
_____________________________
Director of Services
Date:
______ November 2012
EPA Export 01-07-2013:23:45:34
12/234
___ November 2012
Pat Byrne,
Senior Inspector,
Officer of Climate, Licensing & Resource Use
Regional Inspectorate,
Inniscarra, Co. Cork
Re:
Planning and Development Acts, 2000 - 2010
A Chara
Co
n
se
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.
I refer to correspondence received from you in connection with an application by Michael
Dalton,Manager of Tankerstown Pig & Farm Enterprise,Tankerstown,BanshaCo. Tipperary,
for PERMISSION FOR RETENTION for the following developments: (a) Retention
Permission to retain the North Weaner House Extension and (b) Retention Permission to
retain the South Weaner House Extension - constructed on site (c) Permission to construct
new Dry Sow House (d) Permission to construct new extension to Farrowing House: with all
associated site works, in order to comply with animal welfare regulations - as per S.I. No. 48
of 2003. These developments are for the purpose of an activity in relation to which an
integrated pollution control licence is required (Note: This application and Proposed
development will not increase the number of animals on site) at Tankerstown Bansha,Co.
Tipperary and South Tipperary County Council having taken your submission into
consideration decided to CONDITIONAL permission. I am attaching for your information a
copy of the Council’s decision.
Please note that you have the right of appeal to An Bord Pleanala against the Council’s
decision on this application. Your appeal should be addressed to An Bord Pleanala, 64
Marlborough Street, Dublin 1 and should include, your name and address, details of nature
and site of the proposed development, the name of the Planning Authority, the planning
register number and the applicants name and address. The appeal must be received by An
Bord Pleanala within 4 weeks beginning on the date of the Council’s decision.
The full grounds of appeal and supporting material and arguments must be submitted from
the start. The correct appeal fee must also be enclosed (See Attached Schedule). If an
appeal does not meet all the legal requirements, it will be invalid and cannot be considered
by the Board.
Mise le meas,
_____________________
T. O’Dwyer
Administrative Officer
PLANNING
EPA Export 01-07-2013:23:45:34
12/234
___ November 2012
Grainne Leamy,
NRA,
St. Martins House
Waterloo Road
Dublin 4
Re:
Planning and Development Acts, 2000 – 2010
Co
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o
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.
A Chara
by the Board.
Mise le meas,
_____________________
T. O’Dwyer
PLANNING
EPA Export 01-07-2013:23:45:34
12/234
___November 2012
Andrew A Wilson,
Senior Track & Structure Engineer,
Limerick Junction Station
Co. Tipperary
Re:
Co
n
se
nt
o
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
he
ru
se
.
A Chara
by the Board.
Mise le meas,
____________________
T. O’Dwyer
PLANNING
EPA Export 01-07-2013:23:45:34
12/234
___ November 2012
The Manager,
Development Applications Unit,
Department of Arts Heritage & The Gaeltacht
Newtown Road
Wexford
Re:
Co
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o
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ig pe
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ow ion
ne pu
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eq os
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re o
d nl
fo y.
ra
ny
ot
he
ru
se
.
A Chara
by the Board.
Mise le meas,
_____________________
T. O’Dwyer
PLANNING
EPA Export 01-07-2013:23:45:34
EPA Export 01-07-2013:23:45:34
se
Co
n
f c Fo
op r i
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ig pe
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ne pu
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ra
ny
nt
o
se
.
ru
he
ot
EPA Export 01-07-2013:23:45:34
to
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en
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.
Pin Ref 12/234
Planning Section
RECOMMENDATION ON PLANNING APPLICATION
12/234
Applicant:
Michael Dalton
Development Address:
Tankerstown, Bansha" Co Tipperary.
Development:
(A) Retention Permission to retain the North Weaner
House Extension and
(B) Retention Permission to retain the South Weaner
House Extension - constructed on site
(C) Permission to construct new Dry Sow House
(D) Permission to construct new extension to
Farrowing House: with all associated site ""arks;
Proposals are in order to comply with animal welfare
regulations - as per 5.1. No. 48 of 2003.
f c Fo
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PI Ref
nt
o
These developments are for the purpose of an activity
in relation to which an integrated pollution control
liEeHEe is fetluifed.
Co
n
se
(Note: This application and Proposed development will
Hot increase the number of animals on site)
- --
I.GENERAL:
A notice reguiring further information was issued by South Ti.e.eerary County
Council on the 14th August 2012. A reply to the further information was received on
the 29 th September 2017 and was considered incomplete 8 complete further
information response was received on the 16th October 2012 and was accompanied
by notices of significant further information.
Unsolicited further information was received on the 22nd October 2012.
2. SUBMISSIONSLOBSERV ATIONS:
Submissions received from the following:
---
th
I. Environmental Protection Agency (EPA). 15 August 2012 and 24th October
2012.
....---'
.
The following points were made:
1I
EPA Export 01-07-2013:23:45:34
Pin Ref 12/234
Existing activity is of scale that requires an IPPC License. IPPC License received by
the EPA on 2ih July 2012 in respect ofa 1,000 sow integrated unit and is currently
under assessment. This application was made by Tankerstown Pig and Farm,
Enterprises Ltd. Tankerstown, Bansha, Co. Tipperary and was accompanied by an
EIS. The EIS submitted appears to be the same EIS as that submitted with PI Ref
12/361.
Submission were received on the original proposal by the following:
1. National Roads Authority (NRA).
2. Iarnrod Eireann aID.
3. Department of Arts. Heritage and the Gaeltacht (DAHG).
No further submission has been received from these consultees to date.
ru
Proposed attenuation system in accordance with Council
requirements. Calculations appear in order.
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Water Services:
se
.
3 REFERRALS:
4. ASSESSMENT:
.
tl le f
tiltl
leI'II Ifannation received relative to the items of
This
section wIl. I exanune
further information as requested.
The Planning Authority have reviewed the drawings submitted as part of the
previous planning application P3.10558 which was in respect of an animal
slaughter house and note that that thefarm/piggery bUildings layout shown on
the drawings submitted with this application differ significantly trom that
shown on the site layout plan submitted with the subject application.
Co
n
se
nt
o
1.
Furthermore available ordnance survey aerial photography from 1995, 2000
and 2005 shows that new buildings have been constructed on site post 1995.
There is no record of any planning permission for development on this site
other than P 3.10558.
The applicant is requested to identifY structures that were altered
significantly, and/or enlarged, changed in use and new structures constructed
since the date (?f grant qf P3.10558.
Where the has been a material change to the existing farm structures,
planning permission for retention of these structures will be required.
The further information submitted received on the 26th September 2012 and the 16th
October 2012 includes drawings that identifies buildings/structures that are to be
21
EPA Export 01-07-2013:23:45:34
Pin Ref 12/234
incorporated into this application. n~..strJ1ctures are listed in the follqwing table and>
those proposed for retention are outlined in blue. The structures/buildings outlined
in red C;;e those or1grnaIIy proposed lor retention ....The building/ structure outlined in
green are proposed for permission. The numbers in the left hand side column of the
table corresponCi with that identifi~d on the site layout plan received on the 26 th
September 2012:
--
I)
, Jh
(,
2+-2~
2h
20
2q
J,(l
/':;
21
r----.
1------.
Area
--
231) 7 ~q III
2K-i.7 'iq m
:;:--1 sq m
hq:~ J)
: I...l) 111
5.1,K,Q" "q
-..
_-----.-
--'-
111
--~--
r
.h.f
3h.7:;
"y
m
--
"<1111
sq m
l2.K sq III
15,1 q ~q 111
,)(l.h
-----------~--
--
133 sq m
IB
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ru
if-\.
ot
,I
Description
Gilt house
Dr\' Sow House
Finishing house
Stuck housl'
Silagl' Apron
FUI.:'1 Tanks
\VeiKh bridge house
VVeigh bridge
Pump house
Boi ler houst'
Intake Hopper
South
weaner
House
Extension
North
weaner
House
se
.
BuildinlifStructure No.
l::;· ...
2,'\
--
241.6 sq
tTl
l-n .c',,, ....
-.
Farrowing House
ury :>ow 11.0use
Rainwatt'r
a ttt'nua lion
Svsl:em
-
26 l. 00 SCI m
KYh.-i2 SLI m
--
--
.-------~-----
Co
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"
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fo y.
ra
ny
I
The notices of significant further information include for the above identified
structures and also mcludes pertnlssion to retain for the modification of the site
boundary.
I have inspected the sjte on the 31 st October 2012 and I note the following
discrepancies between the drawings received of the additional structures/buildings
for retention and that as consh acted OIL site:
i) The drawings of the bunded fuel bay (No. 28 on site la out Ian does not
correspon WIt t at on site. There are 4 no. fuel tanks mounted on a bund.
Only 2 no. are shown on the drawings submitted. The plan of the fuel bay is
accurate.
ii) The drawings provided for the stock house (no. 24 and 25 on site layout
plan) does not accurately reflect the building on site. The principal
dimensions of the building are consistent but the elevation drawings show
existing vent stacks that are not reflected on the as constructed building. Also
the roof of building no. 24 does not correspond with that as constructed.
iii) Drawing No. 104 and 105 have been labelled as building no. 15. I have
contacted the applicants agent regarding this matter and he confirmed that
one set of drawings has been incorrectly labelled. The drawings provided do
not accurately show the vent stacks on these buildings.
31
EPA Export 01-07-2013:23:45:34
Pin Ref 121234
The above discrepancies are considered minor in nature. I have inspected the
structures on site and consider same to be acceptable in terms of design. Accurate
drawings can be requested by way of condition so that Council records are complete.
1.-/
In addition to the above further structures and buildings were constructed on site
post those shown since the date of grant of P3.l0558. These buildings are labelled as
no.'s 1-5,7,-12,14. 17-18,20. The further information submission received on the
26 th September 2012 includes a schedule of development of farm structures
identifying when structures were developed on the farm and citing planning
exemptions under which the structures/buildings were developed,
I have copied the relevant statutory instruments that provided exemptions for the
construction of structures no's 6-7, 9-12, 14, 17, 18 and 20, which are:
• SI
236 of 1964
Local Government (Planmng & Development) Act
1963 (Exempted Development) Regulations 1964
• SI 176 of 1967 Local Government (Planning & Development) Act 1963
(Exempted Development) Regulations 1967
ot
he
ru
se
.
I conSIder these structures avail of the planning exemptions prO\;ided under the above
mentioned statutory instruments.
The Planning Authority note that Tankerstown Pig & Farm Enterprises Ltd
have applied/or an IPPC License (Reg P0965-01j, This application states that
the operational sow numbers on the fat mate 9QO (fi om 700) and that that a
planning application is being madefor 1000 sow places,
Co
n
se
nt
o
2,
f c Fo
op r i
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ig pe
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eq os
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I spoke withrhe applicants agent Michael Mclnery on the 30-10-2012 who identifies
that structures labelled 1-3 have been in existence pre 1964. In addition to this the
well that sen es as water supply for the site and the septic tank for the dwelling are in
existence pre 196~
c..---The JPPC License application states that an Environmental Impact
Assessment (EIA) included with the IP PC License application is also made in
support of a planning application. The details ident~fy that the proposed
planning application consists of the demolition of3 no, fattening houses and 1
no, machinery shed and to construct 8 no, new pig fattening houses, a loading
hay, a new machinery shed and to provide additional space for stock numbers
and to comply with animal we(fare regulations, This development description
differsfrom that proposed in the subject application.
In view 01' the foregoing the applicant is requested to provide a chronology (~I'
development undertaken on the site post 1960 and give details ofpiggery type,
stock numhers and capacity relative to the chronology ofdevelopment.
The applicant is requested to clar~ whether the planning application referred
to in the Tankerstown Pig & Farm Enterprises Ltd IPPC License application
41
EPA Export 01-07-2013:23:45:34
Pin Ref 12/234
(Reg P0965-01) relates to the subject planning application. In particular the
applicant is requested to clarify whether the increase in pig farm capadty 10
1,000 sow places is proposed as part of the subject application.
The Planning Authority advise that increase in 'placesfor sows' may give rise
to the requirement jor Environmental Impact Assessment or EIA Screening
The Planning Authorityfurther advise that Section 34 (12) of the Planning &
Development Acts 200-2010 preclude same from considering an application
for retention permission that would require, EIA, EIA Screening or
Appropriate Assessment (AA).
The further information submission received on the 26th September 2012 provides a
chronology of development on this farm. These details provide the breakdown of
stock numbers on the farm in place at 1990. The details provided show the facility
accommodated 203 farrowing sow places, 500 dry sow places and 150 served gilt
places in 1990.
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.
The Decision of the European Comt Case C5985-10 changed the definition of a sow
to include served gilts, which the further information submission of 26 th September
2012 identifies gIlts numbers as ranging from 15%-25% of the sow herd. This gives
rise to an increase of places for sows by 175 maximnm (501<''' herd 700 approx).
The current standards for EIA for pig production facilities is set out under Schedule
5 of the 2001 Planning and Development Regulations, as amended. Item no 1 (e)(ii)
of Part 2 of the fifth schedule of these regulations refers to:
Co
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se
nt
o
Installations for intensive rearing of pigs not included in Part 1 of this
schedule, which would have mOle than 2000 places for production pIgS (over
30kg) in a finishing unit, more than 400 places for sows in a breeding unit or
lIlore than 200 places for sows man mtegrated unit.
k
Class 13 of the Planning and Development Regulations 2001, as amended, set
out EIA thresholds for changes or extension to developments as follows. This
threshold came into force in 1999 and is as follows:
(a) Any change or extension of development which would
(i) result in the development being of a class listed in Part I
paragraphs 1 to 12 of Part II of this Schedule, and
0]'
(ii) result in an increase in size greater than-25%, or
- an amount equal to 50% of the appropriate threshold,
whichever is the greater.
5
EPA Export 01-07-2013:23:45:35
Pin Ref 12/234
In the subject case and on the foot of the European Court case Case C5985-10 it
appears that the places for sows numbers has increased by 175 places, from 700 in
place pre 1990. This represents an increase of 25% of places for sows and exceeds 50%
of the appropriate threshold for the intensive rearing of pigs, which requires EIA for
more than 200 sows in an integrated unit.
In order to address this and bring the places for sow numbers below the required
EIA threshold to numbers that existed in 1990 prior to the introduction of thl;;' EIA
Directive. The applicant has entered into an agreement with
. a ~ Denis Moran to,
relocate Gilts from this facility off site until they enter the farrowing house and it is
proposed to maintain this ag~ement until the IP[,C License application and separate
J~.!~2ng application
has beel; pIOC€~.~.~~d. The ~parate planning ~ppliCation PI Ref
has tJeen lodged ~ proposes to increase the capacity of this facility to a
1,000 sow integrated unit. This application is accompanied by an Environmental
iLj 51) 1
Impact Statemellt.
se
.
I consider this approach as reasonable and recommend a condition be attached that
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this permission does not alIo...? for an increase in stock numbers from that in place jn
the 1990 with places for sows numbers maintained at no greater than 700 at any
given time.
nt
o
3. The Planning Authority advise that the proposal involves development within close
proXImIty to the Rwer Aherlow WhICh IS a Special Area of Conservation (SAC) and Natura
2000 Site. The Planning Authority note that waters from the site drain to the Aherlow River
channel.
Co
n
se
The Planning Authorihj consider that there is insufficient information in the application to
allay concerns regarding potential ikleterious matterjliquid run off to the river and there is
insllfficient information regarding what, if any, mitigation measures that are in place to
prel'ent same occurring
Accordingly the applicants are requested to arrange to submit, for the consideration of the
Planning Authority, a Natura Impact Statement of the proposed development. This should be
undertaken in accordance witiz 'Appropriate Assessment of Plans and Projects in Ireland Guidance for Planning Authorities' published by the DoEHLG in December 2009.
I have undertaken a screening of the proposed development for Appropriate
Assessment. This examines the development proposed for retention and that
proposed for permission. The screening assessment is attached as Appendix 1 and
identifies impacts on the SAf are unlikel~. Therefore an Appropriate Assessment of
the development is not required.
-
1 note that the further information received on the 26 th September 2012 includes an
~pp~priate Assessment Screenin~ Report: I note the development description in
this report does not correlate with the development as proposed. This Appropriate
Assessment Screening Report relates to the development proposed under PI Ref
-
61
EPA Export 01-07-2013:23:45:35
Pin Ref 12/234
12/361 and not the subject proposal. Notwithstanding I consider there is sufficient
information available to inform the Appropriate Assessment Screening undertaken
and attached as Appendix 1.
t.-/--
4 Please arrange to submit a revised site plan with more detailed drawings of the
rainwater/storm water /clean water collection system. The pipe layouts, sizes and
gradients and existing gullies should be clearly indicated.
The Planning Authority consider that the area of buildings on this site is substantial
and recommend that a storm water attenuation pond or tank with hydrohrake be
installed on site to alleviate flood risk in the watercourse or adjoining lands. The
applicant is requested to incorporate this requirement into the subject application.
Water Services have examined the proposals for storm water management and
attenuation and state as follows:
~e
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se
.
proposed Attenuation is in compliance with South Tipperary County
CounciI's Water Services document entitled Potable Water, Foul and Surface
Water Requirements, A Design and Construction Guide for Significant
Developments. It complies with the 30 year critical storm event attenuation
recommended in that document.
I have checked the calculations supplied for run off and attenuation. The
calculatiOIl!:appear to ~ in order.
ident~fied.
Co
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se
nt
o
5. ,No details r+fejjluent disposalfocilities jor staffwelfiue have been provided. Please
provide details of the existing ejjluent disposal ,~ystem that facilitates the staff'and site
office. The location of this system and details of percolation piping should he
The site office is located within a former dwelling, I have been advised by the
applicants agent has existed pre 1964 and has been used as an office since the
piggery enterprise was in operation on this site which was pre 1964 .....
Wastewater from this office discharges to a 2 chamber spptic tank and
percolation. A condition should apply requiring that the applicant examine
the adequacy of this system relative to applicable EPA 1999 requirements. If
same does not meet current EPA requirements then the applicants can be
requested to upgrade same. ,_
v
6. The Planning Authority requires the following details regarding water supply:
(aJ Please identify ifyou are connected to the public water mains. Please note
that under permission P 3.10558 it was proposed to connecl to the puhlic
mains.
71i
EPA Export 01-07-2013:23:45:35
Pin Ref 12/234
(b) {fyou are connected to the public mains, please indicate tfthis connection
is for domestic or agricultural use. Please provide details of annual
consumption ofpublic water supply if relevant.
The further information identifies that the water supply is via a private well on site. It
is unclear when this well was developed.
5. CONCLUSION:
Having examined the details provided as further information and the details
provided with the application and all internal reports and submission received in
relation to this application I conclude that the development is acceptable for this
location and in the intelests of plOpel planning and sustainable development.
In the interests of clarity this permission IS for the foIIowmg
Plan!ling permission for retention of the following structures:
,Building/Structure No.
--
24_?"i
~-
26
-:"0 .
~
29
30
1-13
-21
----------
--
T.
u
i 1A
E_ _ _
se
...
ns
en
_______.
Co
_£.0
ot
to
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ne pu
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eq os
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re o
d nl
fo y.
ra
ny
Dry Sow House
Finishing house
Stock house
Silage AJ>fon
1.
...E...... _1......'T',• •,-""
Weigh bridge house
Weigh bridge
Pump house
Boiler house
he
lluu~e
16
6
c--
ru
_1::J
,1,
. .~~,~
U.
~
",.-,.-
,...,
£.JU.
F
"'1
UL
284.7 sq m
371 sqm
693.63 sq m
538.93 sg m
--
---
17.64 sqm
~6.7j sq m
30.6 sq m
32.8 sqm
1~10
~~t-'t-'~~
South
weaner
Extension
weaner
North
Extension
I
Area
.
Description
,
\.Jl1l
'---'"
~~.~
,
TY1
House
133 sq m
House
241.6 sq m
--
---
Permission for retention also includes alterations to the site boundaries
Planning permission for:
~ 2A
----------
I~6 .. ---------L
I Farrowing House
i Dry Sow House
Rainwater
attenuation
system
The permission also includes for the installation of a storm water attenuation
system prior to discharge of storm waters off site.
81
EPA Export 01-07-2013:23:45:35
Pin Ref 12/234
No permission:::::'"
is given for any i!!crease in stock I sow numbers
in this piggery.
c.....,
_________________
._______ ,
Where the development requires an IPPC licence, planning authorities are, pursuant
to Section 256 of the Planning & Development 2000 Act prohibited from the
attachment of conditions which are for the purposes of:
(a) controlling emissions from the operation of the activity, induding the
prevention, limitation, elimination, abatement or reduction of those
emissions, or
(b) controlling emissions related to or following the cessation of the operation
of the activity .
As the subject proposal requires an IPPC License the control of emissions as outlined
in parts a) and b) above is the responsibility of the Environmental Protection Agency.
I note that an application for an IPPC License for this facility has been made to the
EPA.
f c Fo
op r i
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ne pu
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eq os
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d nl
fo y.
ra
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ot
he
ru
se
.
6. RECOMMENDATION:
Having examined the application and its supporting drawings and documentation
and having consIdered the impacts of the proposed development and the relevant
policies of South Tipperary County Develo ment Plan 2009, I recommend sub·ect to
at permIssion and permission for retention be
nt
o
Granted
......
,
.,
.
Co
n
se
The area subject to contnbutions IS as follows:
LJUlluln):;s ror retennon 1~~U.M
Description
BuildinJi$tructure No.
Gilt house
15
Drv Sow_Hov Sf>
16
Finishing house
6
J.
Ulal i\.n::a Ul
2A
(""
'"IJ:::
_1
L
South
weaner
Extension
North
weaner
Extension
lIB
~1
256.7~m
284. 7 <:,' ",
'--'LULl>. HUU.;:>C;
' lA
1
Area
House
371 S9.. m
U7,}.O-J Sl! m
133 sqm
1
-1
,
House
!
241.6 sq m
--~-----------,
Total Area of buildings for permission=1,157.50
Buildin~Structure
2A
26
~----
No.
Description
Farrowin.K House
Dry Sow House
Area
261.08 sq m
896.42 sq m
-
91
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Pin Ref 12/234
Total area of buildings for agricultural use proposed (retention and permission)
3,138.13 sq m.
=
The South Tipperary Development Contribution Scheme states that farm
improvement
works
necessitated
out
of
EU
Farm
Environmental
programmes/ directives are not subject to development contributions. As building
no. 26 is to comply with animal Welfare Regulations same should not be subject to
development contributions. In addition the first 600 sq m of the buildings used for
agriculture is not subject to development contributions.
l----
Total area of buildings for agricultural use proposed (retention and permission) =
1,641.71 sq m .
Co
n
se
nt
o
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
he
ru
se
.
."
101
EPA Export 01-07-2013:23:45:35
PIn Ref 12/234
Planning Section
RECOMMENDATION ON PLANNING APPLICATION
PI Ref
12/234
Applicant:
Michael Dalton
Development Address:
Tankerstown, Bansha" Co Tipperary.
Development:
Permission for retention of the following:
ot
he
ru
se
.
North Weaner House Extension and
South Weaner House Extension
Gilt House
Dry Sow House
Finishing House
Stock house
Silage Apron
Fuel bay and tanks
Weight bridge and weigh bIidge house
Pump House
Boiler House
Intake Hoppel
Altered site boundaries.
Co
n
se
nt
o
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Associated
site
works
including
drainage
at I at 1gen lent.
Permission for following:
•
New Diy Sow House (Proposals are in order to
comply with animal welfare regulations - as per
S.1. No. 48 of 2003.
•
•
Extension to farrowing house
New storm water attenuation system.
(Note: This application and proposed development will
not increase the number of animals on site)
-----------------------------------------------------------------------
111
EPA Export 01-07-2013:23:45:35
PIn Ref 12/234
RECOMMENDATION ON APPLICATION FOR DEVELOPMENT
Having regard to:
[SJ
the nature and extent of the proposed development;
~
~
~
the intended use of the proposed development,
the policies of the County Development Plan 2009 and
the pattern of development in the area,
it is considered that, subject to compliance with the conditions set out in the
attached Schedule, the proposed development;
~
would not seriously injure the amenities of the area or of property in the
vicinity;
[gJ would not be prejudicial to public health;
[gJ
would be acceptable in terms of traffic safety and convenience;
~
would not impact on a Natura 2000 site.
would, therefore, be In accordance WIth the proper plannIng and sustaInable
develorment of the area.
he
ru
se
.
I3J
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
and it is recommended that
.::i.iill.r.~I·Ii!;.s.
be granted to the applicant, subject to the following conditions and reasons:
E
nt
o
CONDITIONS AND REASONS
Save where modifIed by the follOWIng condItions, the proposed development
shall be retained, carried out and completed in accordance with the drawings
and documentation submitted with the planning application on the 22 nd June
2012, as amended by revised plans and particulars received on the 26rth
September 2012 and the 16th October 2012 as further information.
Co
n
se
1.
2.
Within 12 weeks of the receipt of this notice, unless otherwise agreed with the
Planning Authority, the applicant/developer shall pay to the Planning
Authority a development contribution in the sum of £10,506.94 in respect of the
provision of improved road infrastructure.
(i) The amount of the development contribution shall be in accordance with
the following class as detailed in the current South Tipperary Development
Contribution Scheme:
Class 6
Agriculture- in excess
of 600 sq m.
Rate 2012
Roads
€6.40 per m2
Area sq. m
1,641.71 m2
Total
€10,506.94
€10,506.94
12
I
'f.V
EPA Export 01-07-2013:23:45:35
PIn Ref 12/234
Reason: As a contribution towards the cost of the provision of
improved wa~er 5upply & road infrastructure in accordance with the
South Tipperary Development Contribution Scheme 2011-2015
which was adopted, pursuant to Section 48 of the Planning and
Development Act, 2000 by resolution of South Tipperary County
Council, dated 7 February 2011. Such improvements will facilitate
this development.
3.
IrL
Within 12 weeks of the receipt of this notice, unless otherwise agreed with the
Planning Authority, a revised set of elevation drawings to a scale of 1 :200
shall be provided for the as-constructed buildings/ structures labelled as
buildings/structure no.'s 15,16,24,25,28 and 31.
a) Within 12 weeks of the receipt of this notice, unless otherwise agreed with
the Planning Authority the applicants shall engage a suitably qualified
person to examine the septic tank system and determine whether same
complies with the requirements of the EPA 1999 Wastewater Treatment
Manuals-Treatment Systems for Small Communities, Business, Leisure
Centres and Hotels. A report describing the results of the investigation shall
be forwarded to the Planning Authority on completion.
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
he
ru
se
.
4.
Co
n
se
nt
o
b) Should the existing septic tank effluent disposal system not comply with
the requirements of the EPA 1999 Wastewater Ireatment Manuals-Treatment
Systems for Small Communities, Business, Leisure Centres and Hotels. the
applicant shall submit proposals, viz a separate planning application, for the
upgrade of the effluent disposal system to EPA 1999 Wastewater Treatment
Manuals-Treatment Systems for Small Communities, Business, Leisure
Centres and Hotels requirements. This application shall be made within 4
weeks of the completion of the investigation report as required under
condition no. 4 a), unless otherWise agreed With the Planning Authority.
Reason: In the interests of environmental protection and public health
5
a) TIncontaminated surface water runoff from roofs and clean paved aleas
within the farmyard shall be collected separately from farmyard wastes
(slurrYI silage effluent and contaminated / soiled surface water) and shall be
disposed of directly in a sealed system which shall drain to a proposed
surface water attenuation system.
b) The surface water attenuation system shall be installed on site and the
necessary pipe work shall be installed to ensure all uncontaminated surface
waters are collected and drain to this attenuation system prior to discharge to
a watercourse. These works shall be undertaken and completed within 12
weeks of the receipt of this notice unless otherwise agreed with Planning
Authority.
13 I
EPA Export 01-07-2013:23:45:35
PIn Ref 12/234
c) No contaminated surface waters, soiled waters, slurry or silage effluent or
washings from the pig farm shall discharge to the surface water system or
any watercourse, stream or drain. Surface water shall not be allowed flow
onto the public road or adjoining properties.
d) As and when required by the Planning Authority a sample of waters shall
be tested and results of the test submitted to the Planning Authority. The
water sample shall be taken prior to discharge from the surface water system
to the watercourse.
Reason: In the interest of orderly development and environmental
protection.
6.
This permission does not pIOvide for allY illCIease
numbers above existing permitted levels.
ill
stocking rate
OI 150"_
he
ru
The applicant shall ensure that all farm activities within farmyard are carried
out in accordance with the recommendations set out in 51 378 of 2006,
European Commumties (Good AgrIcultural Practice for Protection of Waters)
Regulations, 2006. Storage facilities shall:
• Be designed, sited, constructed, maintained and managed so as to
prevent run-off or seepage, directly in indirectly, into groundwater or
surface water of livestock manure, organic fertiliser, soiled water and
effluellts front dUltgsteads, farmyard manure pits or silage pits
• Comply with such construction specifications for those facilities as
may be approved from time by time by the Mmlster for AgrICulture
and Food.
Co
n
se
nt
o
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yr ns
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ht ct
ow ion
ne pu
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eq os
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ra
ny
ot
7.
se
.
Reason: In the interest of clarity and the proper planning and sustainable
development of the area.
Reason: In the interests prevention of environmental pollution and
protection of waters including groundwater.
8. Farmyard wastes (slurry, silage effluent, milking parlour washings and
contaminated surface water) shall be disposed of by spreading on land in
accordance with 51 378 of 2006 European Communities (Good Agricultural
Practice for the Protection of Waters) Regulations, 2006 (or as amended) and no
such spreading shall be carried out on any land that is within 50 metres of any
school, hospital, church or building used for public assembly or within 30 metres
of any private dwelling house (except the landowners own dwelling) save with
the consent in writing of the owner and, as may be appropriate, the occupier or
person in charge thereof.
Reason: In the interests of orderly development, public health, the protection
of the amenities of the area and the avoidance of pollution of ground or surface
waters in the area.
141
EPA Export 01-07-2013:23:45:35
PIn Ref 12/234
9. The transportation of farmyard wastes (slurry, silage effluent, milking parlour
washings and contaminated surface water) via the public road shall be carried
out in a sealed and watertight tanker/container such that no spillage of
deleterious matter can occur onto the public road. Should such a spillage occur
the developer shall take all necessary steps to clean same immediately.
Reason: In the interest of traffic safety and public health.
10. All oxidisable and galvanised surfaces of the proposed pig sow house and
extension to the farrowing house shall be painted a dark green matt colour or
other dark colour approved by the Planning Authority and the surface shall be
maintained in a neat, tidy and painted condition at all times.
Reason: In the interest of visual amenity.
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
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fo y.
ra
ny
ot
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ru
se
.
11. All existing hedgerow boundaries to the site shall be maintained and
strengthened and all other site boundaries shall be planted with a mix of
deciduous shrubs suitable for hedging and common to the locality (e.g. holly,
hawthorn, blackthorn, ash). A minimum of 20 deciduous trees of native (not
dwarfed) speCIes shall be mcluded in the hedgerow or elsewhere in the
landscaping of the site. Suggested species include ash, silver birch, oak. apple.
scots pine and these shall be in excess of 3.5 metres in height when planted. The
trees shall he maintained indefinitely and replaced if failure occurs. All
landscaping shall take place in the first planting season following occupation of
the dwelling. No leylandii cypress trees shall be permitted on thIS SIte or Its
boundaries.
Reason: In the interests of visual amenity.
Co
n
se
nt
o
12 a) Railway Mounds and ditches to he preserved except where \.\lfitten consent of
IE has been sought and received.
b) No hqmd shall dIscharge or escape onto railway property. Any discharges
under railway property will need agreement with IE/elE
c) Services to cross railway property must be subject of wayleave with IE/cn~.
d) Works on and adjacent to the railway are requued to meet the terms of the
Railway Safety Act 2005.
Reason: In the interests of propel planning and sustainable development.
13. The applicant shall submit a nutrient management plan by the 1st of January
next, and annually thereafter, a revised Nutrient Management Plan. The NMP
shall include the following minimum information:
• Annual production of manure and the nitrogen and phosphorus
content of the manure
• Summary of the farmers receiving manure, if manure is to be exported
off the applicants landholding
• The NMP shall demonstrate that all lands have adequate capacity for
recovery of the manure generated by the facility.
151
EPA Export 01-07-2013:23:45:35
Pin Ref 12/234
•
The NMP shall maintained at the facility, and made available for
inspection, if requested.
7~
'Jonatha~~
=ning
Signed'
Date:
~ -
l
J - "J'.-,p I '-
se
.
____7
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SIgned:
,-~to{o,,-- c
Jim O'Maho~ey S P"iIanlyng.
::J J 1/
I
/ 0, Z
Co
n
se
nt
o
Date'
16
I
EPA Export 01-07-2013:23:45:35
PIn Ref 12/234
Appropriate Assessment Screening of project proposed under Planning Ref 12/234
--------------,--------------------------,---------------------
Site Name
Designation Type
I Site Code
Lower
River
Suir
SAC
_ 002137
f - - - - - - - - - - - - - t - - - - - - - - - - - -_ _ _ _ _ _ _ _ _ _ _ _----"__'____'--=---'--_________________
Development Type
Project
_
------=-----'---'''------'--'----'---'------'--------+------=--:..------------------------------------------------- ----- -
Development Location
Tankerstown, Bansha, Co. Tipperary.
Other Natura 2000 sites
within impact zone
(Distance)
None within impact zone. Site within drainage catchement of Lower River Suir SAC.
i---'--=---'----'---~.:--=--:..~~~::..:..:..----+---'-------=---=---:.::....:..~_=____::.~~__=____'L.!::___=__:...:::..:...!...____'_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Galtee Mountains SAC is within 1Skm of the site but outside the impact zone of same.
---------------+-------------------------------------------------The project provides for permission for retention of the following structures/buildings
•
Gilt House
•
Dry Sow House
•
Finishing House
•
Stock house
•
Silage Apron
ruel bay and tanks
•
Weight bridge and weigh bridge house
he
•
se
.
•
Pump House
D;I
•
Intake Hopper
•
Altered site boundaries.
•
Associated site works includinll rir;:!in;:u;rp ;:!rr;:!mrpmpnt
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•
'~~'I-"V
ot
•
_
•
£'Y~J IV
"
£
I;>;>IV
lUI
•
•
•
•
:,uUl.lU,es/oullamgs
New Dry Sow House (Proposals are in order to comply with animal welfare regulations _
as per ::>.1. NO. 48 ot lUU3.
•
•
I-'
1-''''
Llle
IUIIUWIIIIS
Co
n
se
T.
ru
•
nt
o
Description of the project
The project is located on the site of an existing piggery that has been in place since the
1960 s. The details provided identify that elements of the project were constructed
orior to the introdurtinn nf thp
nirorH,o .
I.;r~
1_:::,
T"':~J'
'-1<::1
"_I . .
>
01 ...
highlighted above.
The site within drainage catchement of the Suir river (SAC) and is located S8m from the Lower
River Suir SAC boundary but is separated from same by a rail line.
The development site has hydrological connectivity with the Suir as all roof waters and clean
waters from the farm drain into a watercourse that drains into the SAC (River Aherlow) 1/2km
east of the site.
I
L----____________L -_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
~
--------------------------------,--:------------------
Consider the potential for direct impacts on habitats
Consider proposed developments within 200m of the SAC
_
----
V/N and Comment
-T-~---'-'----'----------'-'-'------'------'---------'--"___'____ _ _ _ _ _ _ _ _ __ + _ - - - - - - - - - - - - - - - - - - ________ _
1.1 I Could the proposed project -=-__________________________
give rise to direct loss of habitats for which the '--________________________
No _
_
_ _--.J'---_ _ _ _----'--------'-_ _ _---'---_----'--_ _
17
I
EPA Export 01-07-2013:23:45:35
Pin Ref 12/234
--T SAC is d~~ignated, or other habitats occurring within the SAC?
---
!
I
i
,
'-i."2-1 Could the proposed project give rise to increased human usage/access to the
.-
No
I site, which could potentially cause deterioration of certain habitat types eg
woodlands, wetlands or riverbanks. Consider proposals for development of a
large scale within lkm of sensitive woodlands eg large scale residential
II development or hotels. Consider proposals for the development of paths or
cycleways along the river.
I
'1~3-tooes the proposed project involve development of drainage systems?
If yes,
could this cause drying out of wetland or woodland habitats within the SAC?
I
Yes project has existing drainage
system that see's uncontaminated
waters discharge off site. The project
provides for an attenuation system
that will be installed to control the
volume of off site discharges.
Drainage system would not cause
drving: out of wetland or woodland
habitats within the SAC>
--
______ ..J.
Cnnc:itll:>r thp nntpnti",1 fnr ;.... .,."',.+., nn UI",tpr n1J",litv Ulithin thp c;.dC
.,n,
r;"orc
,
<i"ro.,rn.,
"r
nr.,;nc
r"nnorT;"'"
Tho
'0
nr"n".,on
ru
Thoro
he
lira
se
.
Consider all proposed developments within the catchment of the SAC
'---:;- 1
If yes, consider whether there is
f c Fo
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ne pu
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ot
development site and the SAC?
"'+. 'T;~I f"r r. ,,,e+', '1'+;"" rol~+on ;rn,,~r+r ""
m .~I;+.
nt
o
I
"~+,,r
Co
n
se
I
--- - - - - - - - - -
2.2
---- - - -----
23
t-Would the proposed project result in surface water or other discharges
to rivers, streams or drains directly connected to the SAC? If yes,
consider whether the discharges could give rise to increased
eutrophication or other pollution risk within the cSAC. Consider whether
increased surface water discharge could give rise to increased risk of
downstream storm water surges.
Would the proposed project require an industrial waste water discharge
license? If yes, consider the potential impacts of the discharge on water
quality in the SAC.
VA.,
--
---_.-
oon
"",,i<;tina rir:>in:>a';;-
that
"~+,,rc
see's
~
n;erh~r"o
'0'
uncontaminated
,H
ciTt:>
int"
"
watercourse that drains into the River
1\1.,,,.1,,,
ICArl
ro.
,-v. '" 'U'-'"
'1-''''-'
~
.~
.~'
'1
considered unlikely given nature and
.L
;>l.",t:
v'
l.VI';>
U'
'u • .
r\
~I-''-
U'"U"~
impacts not considered likely given
lid
U"l.U Ild "Hid ,t:u
"",t:,;>
v, Iy
discharge to the SAC.
---
No.
.._---
No.
------
Is the proposed project located within a flood zone? If yes, consider
whether there is potential for construction or operational related
impacts on water quality in the SAC; consider whether the proposed
project increases flood risk elsewhere in the catchment and particularly
the cSAC; or increases the risk of stormwater surges downstream.
Are the proposals for waste water treatment in compliance with EPA
requirements?
---2.5
hoo.,
~
system
--- ----- -
2.4
nr";OrT
No.
I
I
II
II
N/a
--~
I
___J
---
18 I
EPA Export 01-07-2013:23:45:35
Pin Ref 12/234
I
-
-----_._-
---
------
--
I
I 2.6
Could the proposed project contribute to cumulative negative impacts on
No.
water quality? Consider the current status of the freshwater system (see
I
,!"ww.wfdireland.ie) .
-~------.-
,
..
2.7
I
,
-
Would the proposed project involve dredging (construction or ongoing
maintenance related)?
-
No.
-----
-~-
I
i
~
._-----
Freshwater Pearl Mussel
3.1
Protection of this species will be achieved by the protection of water
quality (see section 2 above), by the protection of river habitats (see
section 1 above), and by the maintenance of free passage for fish.
.
.. _ - - - - -
Freshwater Crayfish
3.2
Protection of this species will be achieved by the protection of river
our
.u
'J \J~~ J~':"V
.J.
auuvc/.
-----
---~---
-----
. - - -. .
-----
-
-_._---
-
No impacts
I
ot
he
ru
se
.
~
-------
-- -- -
No impacts
-~
I
----- -
--
Consider potential for impact on species
, ;;>peLle;;>
3.3
I
I
I
r
~
...
Lamprey spp. ana I waIte ~haa
Protection of these species will be achieved by the protection of water
qualiIY \see secIion L abOve), by tne protection of river habitats (see
section 1 above), and by the maintenance of free passage for fish.
No impacts
Would the proposed project result in any interference with river banks
within the SAC?
No imoacts
-
-
se
i- utter
I 3.4
fLluuifl!:J .;>Ufff/UfI,
nt
o
r I;;>
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op r i
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ow ion
ne pu
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eq os
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re o
d nl
fo y.
ra
ny
..
Co
n
i
i
I
3.5
Would the proposed project result in increased levels of disturbance to
the habitat of the Otter?
..
No impacts
f-----.!......-----.
Bats
3.6
-._..
Would the proposed project involve the removal of trees, hedgerow or
woodland?
No impacts
Does the proposed project involve the repointing of old bridges or the
restoration or demolition of old buildings or other structures?
No impacts
r··
3.7
------
. _ - - - - _.. _-----
_ _- - - - - L
----
-
----
Habitats Directive Screening Conclusion Statement
19
I
EPA Export 01-07-2013:23:45:35
Pin Ref 121234
Development Type
Project
Development Location
Tankerstown, Bansha, Co. Tipperary.
--1
Natura 2000 sites within impact zone
i
---------li
Lower River Suir SAC
Description of the project
The project provides for permission for retention of the following structures/buildings
•
•
•
Gilt House
•
Dry Sow House
Stock house
•
Silage Apron
Fllel bay and tanks
•
Weight bridge and weigh bridge house
•
Pump House
•
Boiler House
•
Intake Hopper
•
Altered 5ite boundaries
•
Associated site works including drainage arrangement.
ru
se
.
•
he
Filiisl lilig House
•
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ot
•
---1
The project provides for permission for the following structures/buildings
•
New Dry Sow House (Proposals are in order to comply with animal welfare regulations - .as per 5.1. No. 48
•
•
0
nt
o
The project is located on the site of an existing piggery that has been in place since the 1960's. The details
Co
n
se
provided identify that elements of the project were constructed prior to the introduction of the Habitats Directive
The
site within drainage catchement of the Suir river (SAC) and is located S8m from the Lower River Suir SAC boundary but is
separated from same by a rail line.
I
i
The development site has hydrological connectivity with the Suir as all roof waters and clean waters from the farm drain into I
a watercourse that drains into the SAC (River Aherlow) 1/2km east of the site.
~.~
_List any potential impacts on Natura 2000 sites that you have identified.
Development not considered to give rise to impacts on the Lower River Suir SAC or any Natura 2000 site
If there are potential impacts, explain whether you consider if these are likely to be significant
Development not considered to give rise to impacts on the Lower River Suir SAC or any Natura 2000 site.
Conclusion of assessment
J;~!E~!~nt information
provided to carry out I YIN
I Yes
20 I
EPA Export 01-07-2013:23:45:35
Pin Ref 12/234
screening, significant impacts are ruled out.
Project may be authorised.
I Sufficient information is available -t~-;~f~r~1
this screening assessment.
I
The screening assessment demonstrates
that the development does not pose
significant effects on the Lower River Suir
SAC. or any Natura 2000 site.
I
S"ffk;en, ;nfo,m,t;on pco,;ded '0 " ' ' ' ' 0",
YIN
No.
Insufficient information provided to
complete screening. Screening Report or
NIS is required,
YIN
No.
Completed By
,/~}j11i7J,j)
- - - - - - ------
---
screening, potentially significant impacts on
a Natura 2000 site or sites have been
identified. Project must be subject to
appropriate assessment. Natura Impact
Statement required.
----
--
se
.
------ -
,
I
~
-- ..
ot
f c Fo
op r i
yr ns
ig pe
ht ct
ow ion
ne pu
r r rp
eq os
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re o
d nl
fo y.
ra
ny
IF
n,
he
ru
I
-
v
..!.-'
CAV
---
~t(,'\"
-
l.
--
_.
-- -_..._--
Co
n
se
nt
o
,
21
EPA Export 01-07-2013:23:45:35
EPA Export 01-07-2013:23:45:35
to
f c Fo
op r i
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ig pe
ht ct
ow ion
ne pu
r r rp
eq os
ui es
re o
d nl
fo y.
ra
ny
ns
en
Co
se
ru
he
ot
.

Article 14 Reply - Attachment 2

Transcription

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