environmental statement non technical summary · chorley pr7 7dw . proposed ... country planning...

PROPOSED DEVELOPMENTS AT PLOCKS FARM, BRETHERTON GA Pet Food Partners Group Ltd ENVIRONMENTAL STATEMENT NON TECHNICAL SUMMARY The Town & Country Planning (Environmental Impact Assessment) Regulations 2011 (as amended)

SEPTEMBER 2015

Proposed Developments at GA Pet Food Partners Group Ltd, Plocks Farm, Bretherton 2015 Update of the 2009 EIA Environmental Statement, Comprising Supplementary Information

Non Technical Summary 31st August 2015

Produced by : BCA Landscape 19 Old Hall Street, Liverpool L3 9JQ For : GA Pet Food Partners Group Ltd The Albert Suite, Unit 2 Revolution Park Buckshaw Avenue Buckshaw Village Chorley PR7 7DW


Environmental Statement - Non Technical Summary 3

PROPOSED DEVELOPMENTS AT PLOCKS FARM, BRETHERTON GA Pet Food Partners Group Ltd ENVIRONMENTAL STATEMENT : NON TECHNICAL SUMMARY The Town & Country Planning (Environmental Impact Assessment) Regulations 2011 (as amended) CONTENTS Ch. Author / Editor

1. Introduction

GA Pet Food Partners

2. Method Statement

BCA Landscape

3. Purpose of the Development

Steven Abbott Associates

4. Identification of Key Issues

BCA Landscape / Steven Abbott Associates

5. Description of the Development

BCA Landscape

6. Planning Context

Steven Abbott Associates

7. Traffic Impact Assessment

White Young Green

8. Odour Impact Assessment

ADAS

9. Dust Impact Assessment

ADAS

10. Ecology, Biodiversity & Nature Conservation

Pennine Ecological

11. Landscape & Visual Impact Assessment

BCA Landscape

12. Flood Risk Assessment

Amec Foster Wheeler

13. Land Contamination

RUKHYDRO

14. Energy Impact Assessment

Brownlow Utilities

15. Review of Sustainable Water Management

Amec Foster Wheeler

16. Waste Water Management Assessment

WEBS

17. Noise Impact Assessment

Sharps Redmore Partnership

18. Economic Sustainability Assessment

Brookdale Consulting

19. Archaeological Assessment

Archaeological Services - Durham University

20. Waste Impact Assessment

GA Pet Food Partners

Appendices

A List of Plans included with the Environmental Statement

B Plan 11G – Masterplan Plan 12 – Overall Masterplan 14.505-100 – Planning Application Boundary



CHAPTER 1 – INTRODUCTION

1.1 This document is a non-technical summary of the updated Environmental Statement produced for the proposed developments at Plocks Farm, Bretherton.

1.2 In 1992, the applicant, GA Pet Food Partners Group Ltd (GA), began processing wheat

grown at Plocks Farm, located between Preston and Southport on the A59 midway between the villages of Tarleton and Much Hoole. The business manufactures dry pet food : it has been a tremendous success and employs 439 people with a turnover in excess of £73m, of which 34% is exported to 37 different countries.

1.3 This industry is continually improving its standards of quality and performance, and to

address such changes and to maintain / improve its market position GA regularly undertake a review of their facilities : these have been carried out in 2003, and in 2009 when a more comprehensive development plan was supported by a full Environmental Impact Assessment (EIA). A further review has been carried out in 2014 - 15, identifying further changes and development of production facilities : the Environmental Statement (ES) submitted in support of the 2010 Planning Permission has also been reviewed and updated to consider the potential impacts of the revised development strategy. . The 2015 Masterplan which emerged omits some of the approved buildings (not yet constructed) and introduces new ones relevant to GA’s requirements for the next 10 years

1.4 The Planning Application boundary is included in the Appendix as drawing 14.505-100. 1.5 This Report is a Non Technical Summary of the 2015 Update of the 2009 ES, prepared in

accordance with the EIA Regulations

CHAPTER 2 – METHOD STATEMENT 2.1 The development proposals have been prepared for GA Pet Food Partners Group Ltd

(GA) by a team of specialist consultants 2.2 Since 2003 GA have adopted a ‘Masterplan’ approach to the development of their facilities

at Plocks Farm, and the current application is the result of the third review, the first and second in sequence (with Planning Approval references) being -

i) The 2003 Masterplan, approved in May 2003 (Ref. 9/03/00528/FULMAJ).

ii) The 2009 Masterplan, approved in March 2010 (09/00738/FULMAJ) : the scope of the development proposals envisaged fell within Schedule 2 of The Town & Country Planning (Environmental Impact Assessment) (England & Wales) Regulations 1999 (the1999 EIA Regulations), thus the Application was supported by an Environmental Statement (ES).

This planning permission is referred to as the 2010 Permission in this Summary

2.3 In 2014-15 GA carried out a further review of their facilities and the development of the

business since the 2010 Permission : a prime influence on this has been the opportunity to acquire storage premises at Buckshaw Village in Chorley, thus reducing the requirement for warehousing at Plocks Farm and opening up other opportunities. A further issue is the need to respond to changing requirements and standards from GA’s business customers and regulatory bodies.

2.4 In Pre-Application and scoping discussions between GA and Chorley Council (CC) it was

agreed that the 2015 ES should update and supplement the 2009 ES.



2.5 To follow the standard procedures, a Scoping Document based on this approach and setting out the principles of the 2015 development proposals was submitted to CC 30th April 2015 (reference15/00416/SCOPE). A formal Pre-Application submission was also made on 30th April 2015 (reference 2015/00077/PREAPP), and together these identified the key issues to be addressed by the ES

2.6 The first draft of the Masterplan was the subject of consultation with local residents early in

July 2015. Feedback was received by questionnaire, and has been incorporated in to the final proposals. The process is recorded in a report (the "Statement of Community Involvement" included with the ES as an Appendix to Chapter 2 CHAPTER 3 – PURPOSE OF THE DEVELOPMENT

3.1 The 2009 ES explained the objectives for further development for which planning

permission was then required, summarising that these had to respond to - i) environmental legislation ii) the requirements of its customers iii) the expectations of the community of which it forms a part. 3.2 Following the 2010 Permission GA has been successful in the following areas -

i) Increasing employees from 250 to 439;

ii) Occupying a distribution centre at Unit R2 Buckshaw Village, Chorley, reducing traffic movements through Bretherton and Chorley Borough. As a result, the onsite approved Automatic Finished Product Store (AFPS) is no longer required.

iii) The approved infrastructure for odour control has reduced complaints from an

average of 110 per annum up to 2010 to a total of two per annum for the years ending 2013 and 2014. Odours are now reduced to 20% below the stipulated limit, and as a consequence, the approved 30m high chimney is no longer required.

iv) Noise has been reduced by 30% as a consequence of good practice, design in buildings and the erection of an acoustic fence within the complex.

v) Annual monitoring of the landscape shows that site biodiversity has increased. vi) Rainwater from yards and roofs is recycled for use in the manufacturing complex.

3.3 GA’s growth has exceeded expectations : the business continues to grow, and now needs to build 18% more new floor space at Plocks Farm (after taking the expansion permitted by the 2010 Permission into account). The purpose of the floor space also needs to change to reflect GA’s current requirements.

3.4 The 2015 Masterplan thus reflects GA’s current objectives -

i) To have the ability to prove the provenance of every raw material included in every bag via an enquiry over the internet.

ii) To use fresh, unprocessed meat from known sustainable sources, to allow the

preparation of specialist premium pet food now demanded in world markets.

III) To ensure that the storage of raw ingredients, the cooking and packing of the pet food is as hygienic and free from contamination as possible, in accordance with “Good Manufacturing Practice”.



iv) To ensure that the process is fully flexible and efficient so it can compete on the world market.

v) To ensure that the impact on the local community, in terms of traffic, noise, odour

and visual amenity is minimised, while offering a source of local employment that creates economic activity in a rural area.

3.5 GA’s proposals are consistent with the Government’s policies towards the sustainable

growth of the economy, particularly those based in rural areas. 3.9 The current GA plan will enable the Company to meet the qualitative demands in its

market which have become more prevalent since the 2010 Permission -

i) The requirement for complete ‘traceability’ of the source of materials throughout the production process, proving the provenance, and building trust and confidence in GA’s customers’ branded projects.

ii) Good Manufacturing Practice for high quality food necessitates the elimination of

‘bacteria transfer’ (primarily salmonella ) possible between the collection of raw materials and the production of the finished product. The isolation of all raw materials from the finished product is essential to prevent the risk of cross contamination. As a consequence, there is a need to accommodate more processes within the complex at Plocks Farm and achieve separation between them. This has influence on the layout, reflected in the new Masterplan.

iii) More rigorous testing of products is required before they are released for sale. iv) Given the expansion in the number of ingredients and the number of different bag

sizes, it is more efficient to place product into the final bag “just in time” ready for despatch, rather than store the many varied types - hence the need to provide onsite storage for 14,500 550 kilo bulk boxes.

v) A Combined Heat and Power Plant (CHP) will allow GA to generate its own

electricity from both natural gas and digested waste. The heat generated by that process can be recovered and used in the process. GA estimates that this would reduce its carbon emissions by 4,000 tonnes per annum.

3.10 As in 2009, the purpose of the proposals is that they are based on an update of a

comprehensive, long term plan influenced by a combination of mutually beneficial business and environmental factors. It was recognised by the Council and Secretary of State as sustainable development in 2009. It is sustainable development in the contemporary context too.

3.11 In summary, the proposals will enable GA to develop innovative products to satisfy the

exacting needs of its business customers. GA can continue to minimise its impact on the environment, not just in order to respect the local area and community but to meet its regulatory requirements. The current plans will allow all stakeholders to know what to expect and how the site is to be developed



CHAPTER 4 – IDENTIFICATION OF KEY ISSUES 4.1 As noted in Chapter 2 the EIA process for the Plocks Farm development had already been

agreed with CC during the 2009 application. The 2015 submission repeats the procedures. 4.2 Section 2.5 above notes the submissions of a Scoping Document and the Pre Application

submission in April 2015. The planning officer’s response accepted that there are elements which have planning permission and are yet to be constructed, but advised that the proposals -

i) Represent ‘inappropriate development’ in Green Belt policy terms and as such a

robust and comprehensive planning case is required to justify the proposals ii) Would be determined in accordance with a national and local policy priority which

enables the progression of rural businesses along with job generation and supporting businesses at a local level.

The application should respond to those two areas of policy, common to the both the

adopted development plan and the NPPF, and must clearly set out the changes since the 2010 Permission, clarify the reasons, and identify the issues which the business currently faces.

CHAPTER 5 - DESCRIPTION OF THE DEVELOPMENT 5.1 The development proposals will continue to progress a sustainable production process:

GA propose to construct the following facilities (the references are to the Masterplan drawing 11G in the Appendix) -

i) The Ingredients Kitchen (45) (on the site of the approved AFPS) where raw

materials are ground and blended into a fine powder ready for cooking.

ii) The Larder (48) to contain 14,500 boxes containing 550 kilos of dry extruded pet food to store the 500 different pet food products, incorporating a Laboratory for testing prior to packaging for the customer.

iii) The Meat Kitchen (46) where fresh meat is prepared by pasteurising and

dehydrating to extract the meat flavours to improve the palatability for pets. iv) The Fridge (47) for the storage of meat products for adding to the ingredients mix v) An Anaerobic Digestion Process (54) to allow the recovery of methane gas from

the liquid waste and thereby avoid the need to spread this on agricultural land. vi) The Combined Heat and Power Plant (CHP) (50), to be able to utilise the

methane gas produced, together with natural gas, to generate on-site electricity and utilise the 90Oc hot water produced within the process.

vii) Flood defences - repairs (and raising by up to 0.7m) of the River Douglas flood

bank, which has settled since its construction 40 years ago. viii) The relocation of the approved office building (14) and secure private car park (8)

to the north of the existing access road from the A59. ix) 5m high Acoustic Fencing within the complex

5.2 The development will also complete two areas of woodland planting, postponed during

earlier phases : one in the north was delayed in anticipation of the flood bank improvement, the other (in the south adjacent to the A59) was required to provide temporary working areas for previous construction contracts.



CHAPTER 6 - PLANNING 6.1 GA’s substantial industrial complex at Plocks Farm has grown since the original farm

diversification scheme began back in 1993. As well as the existing floor space, planning permission exists in perpetuity for much more and in the event of a refusal of this application there is a realistic prospect that it would be have to be implemented. The current proposals involve an expansion of the built development but when the extant permission is taken into account it amounts to an 18% increase in floor area – which is all within the established 27 ha site.

6.2 The extant planning permission is a major material consideration, such that the matter to

be judged is the acceptability of the net increase i.e. what exists plus the extant permission is the start point.

6.3 The NPPF has been published since the 2010 Permission. Its various policies presume in

favour of the proposed development, as one designed to ensure a sustainable future for GA.

6.4 The NPPF had no effect on the Green Belt development plan policy context. Whilst it is

arguable that paragraph 89 of the NPPF means that the proposed development is ‘appropriate’ in Green Belt policy terms the ES is cautious and treats the proposals as though they are ‘inappropriate’. Very special circumstances exist to justify a planning permission anyway.

6.5 The Planning Chapter (6) explains that the proposals are compliant with numerous other NPPF and development plan policies (contained in the adopted Central Lancashire Core Strategy and Chorley Local Plan). The NPPF and the development plan are material considerations for decision making on the application. All the development plan policies have to be considered as a matter of planning law. Put simply, when this is done, the ‘harm’ to Green Belt is overridden by other material considerations. These are: i) Genuine, sustainable economic development by a major local enterprise which has delivered over many years after each masterplan review ii) The absence of a ‘real’ harmful impact in the Green Belt given the mitigation in place and planned.

6.6 These are the same principles which have led Chorley Council (CC) to grant planning

permissions for GA’s business at Plocks Farm before, although the policy context now is the Government’s ‘growth agenda’, reflected by the NPPF and development plan.

6.7 Fundamentally, GA’s proposals perform the economic social and environmental roles

identified in the NPPF as being required of sustainable development. They also generally accord with the NPPF’s Core Principles, which are represented in the development plan.

6.8 In addition to the NPPF’s and development plan’s support for the proposed development,

the Central Lancashire Rural Development SPD and the Council’s Economic Development Strategy very much presume in favour of the development – seeing appropriate economic growth in rural areas as of high importance. Those policy documents do not enjoy the same weight as the development plan but are material considerations and significant.

6.9 The proposals deliver sustainable development in a rural area and would make a

significant contribution to building a strong, competitive economy. These aspects epitomise the policy support for the development, in principle, even before the particular circumstances of GA’s business requirements are taken into account.

6.10 Chapter 6 also explains that the rest of the ES update and Design and Access Statement

comprehensively demonstrate why no other interests of acknowledged importance are



adversely affected by the proposed development. On the contrary, the assessments demonstrate how sustainable and environmentally responsible the development would be.

6.11 It is also noted that the Applicant engaged early with CC and local people and a statement

of community involvement forms part of the submissions. 6.12 A Planning Performance Agreement (PPA) has been entered into by CC and GA. 6.13 In accordance with national planning practice guidance, GA will be discussing potential

conditions with CC officers.

CHAPTER 7 – TRANSPORT ASSESSMENT 7.1 The Transport Assessment (TA) considers the likely changes in traffic associated with the

development proposals, and forecasts the likely impacts that the proposed development may have on the local highway network. It takes into account the introduction (since the 2010 Permission) of off-site storage for finished products at R2 Buckshaw Village.

7.2 Currently, there is limited capacity for the storage of raw materials and finished product at the plant. In order to sustain current production levels, significant volumes of raw materials and finished product are stored at off-site storage facilities, and this involves additional movements which are undertaken by HGV vehicles and tractors with trailers.

7.3 The proposed development will increase the capacity of storage for both raw materials and

finished product, and will remove the need for the majority of these off-site storage facilities, thereby reducing the associated transport demands.

7.4 Overall, the TA demonstrates that the 2010 Permission (if implemented in full) would have

reduced one-way traffic movements by 80 per day (29,200 per annum), whereas the proposed 2015 Masterplan developments improve this by reducing the daily movements by 99 (36,000 per annum) with thus a greater positive effect.

7.5 Staff levels will not increase as a result of the proposals and so there will be no impact to

employment trips. The site is accessible by most non-car modes and GA implements a Travel Plan which has successfully resulted in a modal shift away from single occupancy car trips and towards travel by sustainable means of transport. The proposals will not affect the trip levels generated by customers making collections.

7.6 In November 2014 a highway improvement scheme was implemented at the Plocks Farm /

A59 junction which changed the configuration of the junction and introduced the ghost island. The scheme also implemented a 40mph speed limit on the A59 at the vicinity of the access to Plocks Farm. The site access to Plocks Farm will continue to operate within capacity and without excessive queues or delays.

7.7 It is estimated that the development proposals will result in an annual reduction of 36,000

trips and a reduction of approximately 355,000 vehicle kms. These trips would have been undertaken by HGVs and so the benefits that this reduction would bring to the local highway network are significant



CHAPTER 8 - ODOUR IMPACT ASSESSMENT 8.1 Following the successful implementation of Phase One of the 2009 Master Plan, being an

Odour Abatement Plant comprising three wet scrubbers with associated biobeds, all of which have achieved the required limit of less than 1,500ouE/m3 at the point of discharge, as monitored on a six monthly basis, the 30m dispersal chimney is not required (this was within the consented Phase Two).

8.2 Phase Three (the construction of Wet Scrubber 4 and 5 and associated biobeds) is currently being constructed and will be commissioned in November 2015. These biobeds have been remodelled with the updated weather data to give the new baseline for the site.

8.3 The 2015 Master Plan proposes a wet scrubber and biobed for the Ingredients Kitchen (Biobed 6), and a further biobed for the effluent air from Waste Water Treatment Works No. 1 (Biobed 7), both of which will require approval by the Environment Agency under the site’s Environmental Permit.

8.4 The modelling of the three existing biobeds, plus the further two currently being constructed, plus the further two biobeds at the Ingredients Kitchen and WWTW1 has demonstrated that for the existing, consented and proposed developments the five year average annual 98th percentile hourly means odour concentrates are below the suggested benchmark range of 3 to 5 ouE/m3 at all residential properties. It is therefore concluded that the proposed developments (being Biobeds 6 and 7) would not result in any significant loss of local amenity.

CHAPTER 9 - DUST IMPACT ASSESSMENT 9.1 The Company has implemented and is constructing a range of extraction and abatement

measures as part of the 2009 Masterplan including dust filtration filters and water scrubbers and biofilters which provided effective control of process and fugitive dust and particulate emissions.

9.2 Further dust abatement measures are planned as part of the new 2015 Masterplan

development : the overall risk of adverse dust impacts from production facilities will remain very low, due to the technological measures in place to control them.

9.3 The nearest receptor is the River Douglas 35 m from the process boundary : however, the

nearest potentially sensitive (human) receptors are the dwellings to the east of the A59 (150 m from the boundary), and the village of Tarleton (400 m). Humans using the river for recreational activities would only be exposed to any occasional dust emissions for very brief and transitory periods, which will in any case be dependent on wind direction.

9.4 DEFRA Process Guidance Note 6/24b for Dry Food Pet Manufacturing Process

recognises that emissions of dust may arise from the processing and size reduction of dry materials, and other emissions may arise when potentially dusty materials are discharged into hoppers, conveyors etc. on delivery of the raw materials. The production processes at Plocks Farm are all undertaken within enclosed buildings : the buildings have extraction and management systems in place to control dust emissions and therefore these internal sources are not considered to have any potential for off-site impact.

9.5 Environment Agency (EA) document EPR1.00 ‘Getting the Basics Right’ provides guidance for the Environmental Permit procedures, and states that all point source and fugitive emissions need to be identified and measures put in place to minimise or mitigate them. It sets out good management practice to control dust that may impact on receptors outside the site - these cover both physical systems and management systems :



i) Physical systems include carrying out operations inside buildings avoiding outdoor or uncovered stockpiles, and using filters on vents on silos, building extractors and conveying systems.

ii) Where outdoor stockpiles are unavoidable, management systems should include

control measures such as sprays, binders, windbreaks, and careful siting in relation to sensitive receptors : handling operations should be minimised as well as considering avoiding void certain activities when there are high winds.

9.6 The existing facility is currently operated in line with the recommendations set out in the

EPR1.00 guidance. The proposed development at the site will see a number of improvements made to the existing installation and management procedures which will further mitigate the potential for dust emissions.

9.7 The proposed measures are set out below: i) All internal factory and process air associated with new developments will be

collected by a high rate extraction equipment throughout the production areas and thereby contain potential fugitives emissions of dust from the factory buildings.

ii) The three existing wet scrubbers and biofilters will be augmented by two further

identical installations, but designed to treat larger volumes of extracted air to a higher level of effectiveness. Water will be sprayed into the untreated air within the new scrubbers to separate out the particulates and soluble volatile organic compounds prior to more complete treatment by the biofilters.

9.8 The biofilters will comprise a media which will be kept moist to sustain a bio-film on the

media and the bio-bed will be covered in order to maintain even temperatures and to control the rate of evaporation. The low speed of air passing through the biofilter, and the wet media and bio-film surfaces will provide effective control of any particulates which are not “trapped” in the preliminary filters and the water scrubbers.

9.9 The assessment reveals that these technological and management measures to be put in

place will further mitigate the risk of dust emissions impacting on the sensitive receptors, the overall risk being LOW.

CHAPTER 10 - ECOLOGY, BIODIVERSITY AND NATURE CONSERVATION

10.1 The site, excluding the River Douglas, supports habitats of site-local value only. The

habitats directly affected by development include areas of amenity grassland, bare ground, ephemeral/short perennial habitats and a small (approx. 0.25ha) stand of juvenile trees less than 10 years old. The habitats affected are of site value only.

10.2 The River Douglas is a Biological Heritage Site (BHS) and therefore of County

importance. The individual habitats affected include coarse low-diversity MG1 and MG7 grasslands, SM24, SM28 salt-marsh communities and S28 fen. The grassland and fen communities are very common nationally, while the salt-marsh communities are very common components of upper salt-marsh zones in the UK. Were these habitats to be evaluated outside the BHS, they would be of site-local importance only.

10.3 The construction phase (raising the flood bank) will have a slight adverse effect on the BHS.

10.4 The effects in all instances are reversible, and can be managed through a range of

precautionary and enhancement measures identified in the site's Habitat Creation and Management Plan (HCMP), which include the following -

i) Restoration of grassland habitats on the river bank.



ii) Woodland thinning/removal of non-native species in immature stands. iii) Improvement / creation of woodland-edge habitats at the amenity grassland /

woodland interface.

10.5 The bird fauna of the site is unremarkable, typical, and of site-local value only: there are no adverse impacts predicted in association with the development.

10.6 The site overall is predominantly devoid of bat roosting potential, and the main areas where potential bat roost sites have been identified are the mature trees and specific buildings - these will be avoided by the development.

10.7 In terms of bat foraging areas, the main areas with foraging potential are located away from the development. Potential foraging areas directly affected by the development are poor; the better foraging sites are not affected by any of the proposals, and there is no loss of foraging overall.

10.8 The HCMP will ensure that the habitat potential for nesting birds and bats is enhanced by

the improvement of the woodland-edge interface with the amenity grassland, including dead-wood habitat for invertebrates as an enhanced food source.

CHAPTER 11 – LANDSCAPE & VISUAL ASSESSMENT 11.1 Plocks Farm is set within the floodplain of the River Douglas, tidal as it passes the Site.

The landform is generally level on all quarters other than a slight ridge on the west side : this is the site of Tarleton village, the main settlement. A recent development - Tarleton Lock - has brought the residential edge eastwards to the bank of the Leeds-Liverpool canal (Tarleton Branch). The rest of the area is sparsely populated with scattered farms and individual dwellings.

11.2 The Site is enclosed on the south and east sides by mature woodlands which surround

Bank Hall. The landscape and visual impact assessment (LVIA) for the 2003 Masterplan identified the potential for further woodland planting to enhance this character and to improve the setting : this was carried out at the earliest opportunity, mainly in 2005. It has thus been established for ten years and is continuing to mature as an effective screen to the production complex.

11.3 As a consequence Plocks Farm is already well screened, with the only significant

viewpoints being from the west (Tarleton) side. 11.4 The 2015 LVIA follows the latest standard methodology and considers the potential effects

introduced by the new development; this takes into account the landscape and visual effects predicted for the approved AFPS in the 2009 assessment. As noted in 3.2.ii) above the AFPS is no longer required, but (subject to permission) it would be replaced by a group of conjoined buildings of similar character (the Ingredients Kitchen / Larder / Fridge / Meat Kitchen - summarised in 5.1 above).

11.5 The building design responds totally to the function of the plant and process it

accommodates. The area is larger than the approved AFPS, and higher to the ridgeline, particularly at the east end where the requirements for traceability and quality control result in the provision of tall silos which can store the single load. The ES includes photomontages of the proposal ; these show that the higher ridgeline would just break the canopy of the screen woodland. Overall, the extent of the visibility is assessed as being similar to that of the 2010 Permission, the further five year growth of trees having helped to minimise the impact to a minimal effect. The trees will continue to add height and re-establish the screening, particularly in the view from the Carr Lane roundabout and from the canal bank



11.6 The form of the proposed building complex includes steps in the ridgeline (in elevation) and in the side extensions (in plan): these are exploited by the cladding design, which includes four varying shades of green cladding to emphasise shadow areas and provide lighter bands to break up the mass of the building, particularly in views from the north (from footpaths leading to the Ribble Way).

11.7 Further mitigation will be provided by the completion of the woodland structure planting to

the north (along the east bank of the River Douglas) and to the south (along the hedgerow by the A59).

11.8 The LVIA demonstrates that GA will meet its objective in terms of safeguarding the visual

amenity, continuing to provide a setting for the complex which addresses the potential adverse effects, and which is in harmony with the character of the landscape context

CHAPTER 12 - FLOOD RISK ASSESSMENT 12.1 Paragraph 100 in the NPPF states that flood risk assessments are required for

development on the floodplains of rivers, sites potentially subject to coastal flooding and for developments over 1.00 ha in size. Flood risk assessments should outline whether the proposed development is likely to be affected by current or future flooding and whether it has the potential to increase flood risk elsewhere.

12.2 The assessment has involved liaison with the Environment Agency (EA) (on river/ tidal

issues), Lancashire County Council (on drainage design), and with the Canal River Trust (to consider the potential influence of the Leeds-Liverpool Tarleton Branch).

12.3 The site is located primarily in Flood Zone 1 (low probability of flooding) but includes areas

of Flood Zones 2 (medium) and defended Flood Zone 3 (high). The entire site is defended by a raised embankment, and this will be raised to 7.00 m AOD as part of the application proposals. The assessment shows that overall the site is at a low ‘actual’ risk of flooding, but that a residual risk of flooding remains in the event of flood defence failure.

12.4 Design measures have been proposed to mitigate this residual risk by raising the threshold

and finished floor levels of the proposed buildings to 1.00 m above the existing site level. This would provide a freeboard of 0.70 m above the EA recommended residual flood level of 0.30 m above existing ground level. An outline flood evacuation plan has also been included to ensure that the residual level of risk can also be managed safely.

12.5 An outline drainage system has been proposed for the management of surface water

within the site boundary through the use of rainwater harvesting and existing site storage volumes, and this would provide storage capacity for up to the 1 in 2 year flood.

12.6 Under extreme rainfall scenarios, in which this storage capacity is exceeded or the

drainage system fails, the lowest parts of the site would be allowed to flood in a controlled manner, with overland flow being constrained by topography. These low-lying areas have sufficient storage volume to contain the 1 in 100 year flood plus climate change event under tide-lock conditions, and without causing flood levels to exceed building threshold levels.

12.7 There would be no increased flood risk either to the site or elsewhere.



CHAPTER 13 - LAND CONTAMINATION ASSESSMENT 13.1 The assessment for the 2010 Permission was carried out by ENTEC. The assessment of

potential impacts from the proposed 2015 scheme is carried out by the same personnel now with a separate consultancy (Rukhydro).

13.2 The main change, with a positive impact, has been the replacement of the approved AFPS

and its deep excavation with buildings of more standard construction. This entirely removes the risks posed by water from the deep excavation and water draining from excavated materials.

13.3 There will be a net increase in impermeable areas in the 2015 proposals, and thus a net

reduction in infiltration to ground : with that, there will be reduced flushing of residual contamination from the former wastewater irrigation (this will be reduced by the waste minimisation strategy).

13.4 One new risk from the 2015 proposals is the planned use of ground stabilisation through

piling for building foundations and the construction of concrete / grout Controlled Modulus Columns (CMCs) to support the building floor slabs. However, material will be excavated in far lower quantities than would have been dug for the approved AFPS. The technique means that during construction of the piles and CMCs there are low risks of impacting deeper groundwater with low levels of contamination in the shallower groundwater. The nature of the cylindrical cross section piles and CMC columns also means they are unlikely to provide rapid pathways for groundwater following construction.

13.5 Overall, risks from the proposed 2015 scheme will be less than the approved 2010

scheme, primarily due to the redundancy of the AFPS. 13.6 The four recommendations in the 2009 assessment have also been reviewed -

i) The first recommendation - further site investigation to constrain contamination was not warranted given low risks to human health and the water environment. This recommendation is maintained in this 2015 update.

ii) The second and third recommendations related to water from the deep

excavations and excavated soils. These are now largely redundant due to the removal of the AFPS, although there is still a recommendation to control surface water runoff from construction areas directly discharging to the river without settlement.

iii) The fourth recommendation was that “Health risks to construction workers and site

personnel from their contact with soils, dust and groundwater should be evaluated and mitigated by the construction contractor and GA through use of appropriate PPE, general hygiene and dust suppression.” This recommendation is maintained for this 2015 update.

13.7 The Site Condition Report (H1 risk assessment, Rukhydro, 2011) would be updated to

take into account subsequent site investigation results, together with any reported pollution incidents at the site and control measures for any materials to be used at the site which differ from those proposed for the 2009 proposals.

13.8 This update should be done as part of discussions with the Environment Agency regarding

the Site’s Environmental Permit.



CHAPTER 14 - ENERGY IMPACT ASSESSMENT 14.1 The Energy Act of 2013 has been introduced since the 2010 Permission, and will have

some impact on GA's operations at Plocks Farm. 14.2 While investments implemented in recent years have delivered notable environmental

benefits, the direct consequence has been an increase in the electricity consumption, as for example through the necessary installation of the biofilter beds and water treatment plant. This has resulted in increased levels of carbon emissions, such that the target reductions in Specific Energy Consumption (SEC) demanded by the Climate Change Agreement (CCA) are currently exceeded by 34.6%, with an associated financial implication under the Climate Change Levy (CCL) buy-out arrangements.

14.3 The nature of the production processes and continuous heat demands at Plocks Farm are

well suited to the application of Combined Heat and Power (CHP) technology. The proposed CHP station would deliver significant overall reductions in carbon emissions through the efficient generation of electricity onsite, removing the reliance on the national grid. This would have the following benefits -

i) Waste heat from the CHP engines can be used to supplement on-going production

demands. ii) Based on electricity and gas forecast demands over the course of the 10 year

plan, carbon emissions would be reduced by approximately 25% This is largely achieved by a 56% reduction in electricity taken from the grid, albeit with a 24% increase in natural gas required to fuel the CHP plant.

iii) This will also help to mitigate increased energy costs in the future. 14.4 As a direct consequence of the reduced energy consumption, the level of SEC is forecast

to reduce by 23% during ‘Target Period 4’ (2019-2010) and 33% by 2025, when compared against the current level. This will reduce the margin of failure against CCA targets and help to minimise carbon buyout costs.

CHAPTER 15 - SUSTAINABLE WATER MANAGEMENT PROPOSALS 15.1 The assessment for the 2010 Permission was carried out by ENTEC. The assessment of

potential impacts from the proposed 2015 scheme is carried out by the same personnel now with a separate consultancy (Amec Foster Wheeler).

15.2 The development proposed by GA would increase the existing average daily demand for

process water from 105 m3/day to 210 m3/d (doubling the current demand for 40 m3/d of mains water to 80 m3/d).

15.3 Currently GA uses mains water in its production processes, paying per unit for the water

supplied. This is an overhead that the company will be able to drastically reduce, if not eliminate completely, by harvesting the available rainwater. This has wider environmental benefits including reducing the pressure on water resources in the supply area, and reducing the energy and other costs associated with abstracting, treating, and distributing water to customers.

15.4 Currently, the standard of water management is high : there is an advanced level of

instrumentation installed throughout the site and water flows are monitored on a near real time basis and managed within an Information System. There is also a high level of water reuse on site (7,318 m3) with two waste water treatment plants in operation. Some rainwater is collected and used but the potential for this is currently limited by the existing storage capacity : when this is exceeded, valuable water is lost to the River Douglas.



15.5 The development proposals introduce new buildings which potentially double the opportunity for harvesting rainwater from roofs and other impermeable surfaces. The water management thus aims to -

i) maximise the use of rainwater that can be captured from the building roofs and low

risk yard areas for re-use within the food production process, and - ii) Store runoff from high risk yard areas, prior to anaerobic digestion on site. (The separation of the differing water qualities is to minimise unnecessary treatment). 15.7 The assessment includes a rainfall runoff and storage model that considers the continuous

storage requirement based on the daily runoff generated from rainfall over a 30 year period and the demand required. The runoff generated and storage implications is investigated for five different scenarios -

i) Potential runoff generated (‘yield’) and storage assessment in relation to the

existing roof area and the current demand for water; ii) Potential rainwater yield and storage assessment in relation to the roof area of the

new buildings (taking into account the increased demand for water from the increase in production);

iii) Potential yield and storage assessment in relation to the existing low-risk yard

areas and existing demand; iv) Potential yield and storage assessment in relation to the proposed low-risk yard

areas and new car park area and proposed demand; and v) Potential yield and storage assessment in relation to the high risk yard areas post

development (linked to the development of the anaerobic digestion unit that will also be part of the new development).

15.8 The assessment has provided the following strategy -

i) To provide tanks (noted 53 on the Masterplan 11G) to increase water storage ii) To collect approximately 29,000 m3 per annum of rain water falling on the roofs,

and replace 80m3/day mains water used in the onsite boilers; iii) To collect around 23,000 m3 per annum of rain water falling on low risk yard areas

which will then be treated and re-used 286 times within the process. It will then be discharged to the River Douglas, or lost by evaporation via the biobeds;

iv) Collect roughly 10,600 m3 per annum of rain water falling on the high risk yard

areas which will be stored and contained. It will then be treated by anaerobic digestion, before forming part of the recycled water, which is eventually discharged to the River Douglas or lost by evaporation through the biobeds

15.9 The potential for capturing water currently lost through evaporation remains to be explored.



CHAPTER 16 - WASTE WATER IMPACT ASSESSMENT 16.1 Since the 2009 Environmental Statement (ES) GA has made a substantial investment in

the waste water treatment plant to treat water recycled from the production process and from yard water run-off.

16.2 A new Membrane Bioreactor (MBR) has been installed that treats the effluent to a very

high standard. The treated water is filtered through an ultrafiltration filter and so enables the treated water to be re used in the wet air scrubbers of the odour control. This saves on consumption from the mains supply use, as well as bore hole water extraction.

16.3 Any final effluent that is not re used is discharged to the River Douglas, well within the

existing discharge limits imposed by the Environment Agency. 16.4 A key operational problem with the present treatment plant is that under periods of high

rainfall the hydraulic capacity of the primary treatment plant is exceeded. This leads to high flow and loads being passed to the secondary treatment plant, which in turn becomes over loaded.

16.5 A larger Dissolved Air Floatation (DAF) plant is required in order that higher flow rates can

be treated in the primary treatment plant so that the secondary treatment plant does not become overloaded during periods of high rainfall.

16.6 The proposed anaerobic digester will treat all of the process and contaminated yard water. The process water would be used to slurry solid waste that is presently disposed off site. 16.7 Anaerobic digestion will provide many process and financial benefits - i) It will eliminate the requirement for water treatment chemicals in the primary

treatment plant. ii) The sludge generated on site will be much reduced as the solids will be digested

in the digester. iii) The waste sludge from the anaerobic digester will be pasteurised and so comply

with the PASS 110 legislation. 16.8 This will enable the sludge to be classified as an organic fertiliser, as opposed to a waste

sludge, and so allow it to be used for land disposal. 16.9 The biogas produced from the anaerobic digester would be burnt in the CHP plant and so

generate power and hot water that would be re used in the production plant. The power produced would fall within the Feed In Tariff (FIT) scheme and so provide a constant revenue source; converting what was once waste products into a revenue source.

CHAPTER 17 - NOISE IMPACT ASSESSMENT

17.1 Noise emissions from Plocks Farm are monitored annually in response to Condition 16 of

the 2010 Permission : this established a threshold level of 44dB (LAR) which was not to be exceeded for more than 5 minutes between 23.00 and 07.00 daily for the closest receptors, on Liverpool Road - this standard has been not been exceeded. A full assessment of the levels of noise likely to arise from the proposed developments has been undertaken, and found to be compliant.

17.2 The new development of housing at Tarleton Lock is considered within the assessment,

with additional baseline measurements taken from this location (in April 2015) to supplement those monitored consistently in the Annual Reports since 2010.



17.3 A similar noise limit condition is proposed at Fairview Bungalow, Plox Brow, Tarleton of 39dB (LAr, 15 mins, free-field) between 23:00 and 07:00, and monitored annually, along with the continued annual monitoring at Liverpool Road, Bretherton.

17.4 The proposals do not place buildings any closer to Liverpool Road than was assessed in

2009. The building specification will incorporate proven mitigation measures (such as insulation) as has been successful in earlier phases of development. The assessment demonstrates that the proposals will meet threshold values compatible with national, local, and site-specific values. CHAPTER 18 - ECONOMIC SUSTAINABILITY ASSESSMENT

18.1 This chapter considers the growth and development of GA since the 2010 Permission

2009 and, in particular, its growing contribution to the local economy of Chorley. 18.2 In 2009, GA was employing 209 people and exporting to 37 countries with a total turnover

of £44m in the UK and overseas. Since that time GA has grown strongly. It now employs 439 local residents, exports to 103 overseas customers and has seen total turnover rise to £77m – growth of 75%. GA has opened new distribution facilities in the UK and Poland. The company has aspirations to grow further and needs investment in new facilities and technology to achieve this growth.

18.3 The assessment of national policies relevant to GA shows the development strategy is

completely in line with national policy as it will see investment in high value-added technology to improve manufacturing efficiency, productivity and global competitiveness. GA’s business strategy of investment to boost productivity and export markets to boost overall growth are completely in accord with the Government’s productivity plan ('Fixing the Foundations' 2015)

18.4 Regionally, the Lancashire Strategic Economic Plan (SEP) was published in 2014 as a 10

year plan. Its vision is for an arc of prosperity across Lancashire : it recognises the importance of established economic sectors such as food manufacturing, and highlights the need for skills investment in workers, particularly to encourage technological change. GA, as a growing indigenous food manufacturing business with its distribution function on a strategic site, is totally in accord with the SEP. The proposed investment in new technology will help to create the ‘Arc of Prosperity’ envisaged in the SEP.

18.5 At the local level, Chorley’s Economic Development Strategy 2012-2022 (Refreshed 2014)

sets out priority areas for the period including promoting inward investment and supporting new and existing businesses. CC aims to encourage a range of employment types within the borough : GA is able to offer a wide range of job opportunities with different skill levels plus the potential for progression within the business over the long term.

18.6 By investing in new facilities and technology, the quality of jobs available within the GA

business will increase, making it more attractive to local job seekers, encouraging workers to settle locally for the long term, with associated investment in housing, and spending in the town centre and in the wider local economy.

18.7 Analysis of the home residence of GA’s workers shows that in 2009, 42 workers lived less

than 5 miles from Plocks Farm. Now, that number has risen to 77 while 417 (95%) live within 10 miles of Plocks Farm : the fact that GA continues to have a strong local employee presence means that a large proportion of wages paid to permanent employees will be spent in the local economy, further supporting rural services and businesses. Estimates of this ‘induced impact' suggest that where a business has very strong local supply linkages it can have a multiplier impact in the local neighbourhood of 1.15 - thus, a further 63 jobs are generated in the area



18.8 GA supplies almost 1,000 trade customers across the UK from small pet shops through to large mail order companies and pet food chains. UK sales accounted for £41m of sales in 2013/14. The company has developed an efficient electronic ordering system to enable it to supply small customers with next day delivery as well as servicing major customers with palletised orders. Whilst some manufacturers would seek to impose high minimum order values, GA has seen some of its smallest customers grow to become major players with long term loyalty to GA. In this way, GA supports the growth and development of almost 1,000 SMEs across the UK, each making an important economic contribution to its local area. The distribution and storage facility at Buckshaw is the facilitator of this supply with the opportunity for expansion as the business grows.

18.9 As well as UK orders, GA is a significant exporter with over £21m of revenue (34.5%)

generated by sales overseas in 2013/14. 18.10 GA benefits local suppliers. In 2014, GA spent £42.4m with its top 30 suppliers. Of this

spend, £36m was in the UK and £27.8m was within 50 miles of the site. £6.4m was spent overseas. A number of the top 30 suppliers are based in Lancashire, accounting for £4.9m of spending. In addition, GA spent a further £17.1m across more than 700 smaller UK suppliers.

18.11 The proposals are expected to be entirely funded through the reinvestment of profits from

the business. The construction activity required to deliver the strategic plan will generate temporary economic benefits and can be estimated to support 203 years of construction work, based on an investment value of £31m and the UK average of £153,000 of construction turnover per job in 2013. Given that development will be phased over a 10 year period, this would suggest that the investment programme will support an average of 20 construction jobs per annum. CHAPTER 19 - ARCHAEOLOGICAL IMPACT ASSESSMENT

19.1 The proposals increase the footprint of the development and hence the potential impact on any archaeological resource that may be present. The majority of this footprint is located within the meander of the river, with an additional car park area located in the east part of the site, immediately north of the access road.

19.2 An assessment of the palaeoenvironmental resource on the site was recommended in

2009. This has been undertaken, and evidence recovered indicates that some prehistoric evidence survives at depth. This has been assessed and information on the environment of the floodplain in the early Bronze Age obtained.

19.3 No further significant evidence for prehistoric or Roman activity within the meander of the

river is anticipated. Because of the limited quality of preservation of the remains within the deposits, their limited contextual time span, and lack of potential to contribute to research objectives beyond works already completed, they are considered to be of low significance.

19.4 No archaeological deposits have been identified which require preservation in situ. This

remains unchanged from the 2009 report. 19.5 This work has been completed and no further significant information is anticipated from

further works on the site, irrespective of the larger footprint of the development. No further work relating to the impact on the palaeoenvironmental deposits is therefore recommended.

19.6 The area to the south of the Site access road contains evidence of possible ridge and

furrow agriculture. Archaeological trenching was recommended on this higher land, and it was recommended that the existing earthworks should be recorded. It is recommended that the trenching works are extended to include the proposed new car park area to the north of the access road.



CHAPTER 20- WASTE IMPACT ASSESSMENT

20.1 The Landfill Directive 1991/31/E and subsequent legislation has promoted the requirement for storage of waste at source, and re-usable waste is recovered before sending the balance to landfill. Chorley Council supports this through its Local Development Framework which requires new developments to minimise waste production, adopt measures to segregate waste for recycling, and encourage recycling.

20.2 Waste generation in the GA process is typically 're-work', defined as product which is out

of specification due to size, shape, nutritional value, or moisture content : this has risen marginally since the 2010 Permission (14.6% in 2014). Management procedures are in place to analyse this and provide solutions to reduce the waste.

20.3 'Re-work' with a high moisture content ('Wet Re-work') cannot currently be recycled so it is

being sent to an anaerobic digester in Runcorn, Cheshire. The development proposals will allow this to be returned to the production process, with the balance being treated in the on-site Anaerobic Digester. Methane generated from this will produce 350kW electricity per hour, saving approximately 700 tonnes of carbon per annum. The residual solid waste will achieve the required standard to allow it to be spread on agricultural land as a further by-product of the process.

20.4 Dry waste (such as cardboard/paper, steel scrap, plastic, wood) is sorted on site and

either recycled or taken to landfill. The amount re-cycled has risen considerably, being nil in 2008-09 and 95% in 2014 :

20,5 There has been a similar progress in the recycling of the hazardous waste component, 99

tonnes being taken to disposal in 2011 reduced to 0.05 tonnes in 2014. The proposals will improve the facilities for the sorting, baling, and storage of such waste.

20.6 Chapter 15 has addressed the potential for the recycling of rainwater : this will replace the

mains water supply currently used for the boilers.



APPENDIX A – LIST OF PLANS INCLUDED WITH THE ENVIRONMENTAL STATEMENT

• Baseline - Update of Plans submitted for the 2010 Permission :

01 – Existing Site Layout (July 2015) 02 – Landscape Features (Roads, paths, settlement, houses, etc) 03 – Landscape Structure (Woodlands, significant hedgerows) 04 – Critical Viewpoints Location Plan 05A – VP1 – existing view & landscape development (from field gate, Coe Lane (2005 -15) 05B – VP2 – existing view & landscape development (from Bank Bridge (2009 -15) 06A – VP3 – existing view & landscape development (from entrance to Bank Hall (2009 -15) 06B – VP4 – existing view & landscape development (from Carr Lane Roundabout (2002 -15) 07A – VP5 – existing view & landscape development (from the footpath Haunders Lane to the Ribble Way (2009 -15) 08A – VP7 – existing view & landscape development (view from the canal bank at the bottom of Plox Brow, Tarleton (2002 -15) 08B – VP8 – existing view & landscape development (from the edge of Bretherton Village (2009 -15) 08C – VP10 – existing view & landscape development (from R. Douglas crossing / Bank Bridge (2009 -15) 09 – Plocks Farm – Woodland Planting Development 10 – Zone of Theoretical Visibility (ZTV) (Existing Farm July 2015) • 2015 Masterplan Review - Proposals :

11G – Proposed Development of Golden Acres - Masterplan. 12 – Overall Masterplan 13 – Landscape Proposals Analysis – On Completion : (Note - VP 6 and VP9 not used in this assessment) 14 – LVIA Assessment Matrix - Baseline 15 – LVIA Assessment Matrix - On Completion 16 – VP1 - view from Coe Lane : Photomontage on Completion 17 – VP2 - view from A59, south of Bank Bridge Photomontage on Completion 18 – VP3 - view from entrance to Bank Hall : Photomontage on Completion 19 – VP4 - view from Carr Lane roundabout : Photomontage on Completion 20 – VP5 - view from the footpath Haunders Lane - Ribble Way Photomontage on Completion 21 – VP7 - view from the canal bank Plox Brow, Tarleton : Photomontage on Completion 22 – VP8 - view from Bretherton : Photomontage on Completion 23 – VP10 - view from Bank Bridge : Photomontage on Completion 24 – Zone of Theoretical Visibility (ZTV) on Completion Mitigation : 25 – Mitigation Measures (Buildings) 26 – Cladding - Ingredients Kitchen/Fridge/Larder 27 – Cladding - Meat Kitchen 28 – Mitigation Detail - VP1 (Coe Lane) 29 – Mitigation Detail - VP4 (Carr Lane roundabout) 30 – Mitigation Detail - VP5 (footpath Haunders Lane - Ribble Way)



Analysis – Photomontages of Completed Scheme + 10 Years : (Note - VP 6, VP8 and VP9 not used in this assessment) 31 – Assessment Matrix – Completed Scheme + 10 Years 32 – VP1 – view from field gate, Coe Lane VP2 – view from Bank Bridge 33 – VP3 – view from entrance to Bank Hall VP4 – view from Carr Lane Roundabout 34 – VP5 – view from the footpath Haunders Lane to the Ribble Way VP7 – view from the canal bank at the bottom of Plox Brow, Tarleton 35 - VP10 - view from Bank Bridge SCHEDULE OF DRAWINGS - BUILDINGS (Plan References as per 2015 Masterplan Drawing 11G) 45 - Ingredients Kitchen 46 - Meat Kitchen 47 - Fridge 48 - Ingredients Kitchen Materials Store

Dwg Number Rev

Title

2014-040-P0001 B Site Plan 2014-040-P0002 B Meat Kitchen - Proposed Plan & Elevations 2014-040-P0003 A I / Kitchen - Proposed Plan 2014-040-P0004 B I / Kitchen & fridge - Proposed Elevations

50 - CHP Station

Dwg Number Rev

Title

P2015-018-01 P1 Floor Plan P2015-018-02 P1 Roof Plan P2015-018-03 P1 North East Elevation P2015-018-04 P1 South West Elevation P2015-018-05 P2 Site Location Plan P2015-018-06 P1 Floor Plan (Drainage)

51 - Wet Scrubber 54 - Anaerobic Digestion Plant

Dwg Number Rev

Title

2014-040-P005 A Plant Room, Wet Scrubber & Anaerobic Digestion Plant - Proposed Site Plan & Elevations

SCHEDULE OF DRAWINGS - OTHER DEVELOPMENT - Flood Bank Raising

Dwg Number Rev

Title

P2014-003-01 B Extent of Flood Bank Raising, with Contours P2014-003-02 P2 Sections 2 P2014-003-03 - Not used P2014-003-04 P2 Sections 3 P2014-003-05 P2 Bund Extension Cross Section P2014-003-06 A Location Plan



APPENDIX B – PLAN 11G – MASTERPLAN PLAN 12 – OVERALL MASTERPLAN 14.505-100 – PLANNING APPLICATION BOUNDARY

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