Horham and Southolt Parishes Save Our Countryside (see contact details below)

Nicola Beach Chief Executive Suffolk County Council Arthur Charvonia Chief Executive Babergh & District Council Endeavour House 8 Russell Road IP1 2BX

3rd September 2020

Dear Nicola Beach and Arthur Charvonia,

Intensive poultry unit developments in Mid Suffolk District

Thank you for your letter dated 3rd August 2020, which, as agreed, we circulated to a number of neighbouring parishes for information.

We would now like to respond to a number of comments contained within your letter, under the same headings.

Context

We are very well aware of the UK poultry market dynamics and the historic concentration of the industry within Suffolk but appreciate why you felt it necessary to explain.

In the first instance, we would like to point out that the Animal & Plant Health Agency (APHA) Poultry Population Report contained in Appendix 1 of your letter does not reflect an accurate picture of the true density of poultry units in the county. APHA caveats the report contents by stating that “There is significant uncertainty in the accuracy of the information displayed. The creation of maps from incomplete data results in a high risk of incomplete and or misleading information being portrayed. Similarly, population and holding density maps are classified to different scales and units and due care must be taken regarding their interpretation.” The APHA register records poultry holdings upwards of 50 birds and the data includes a wide range of poultry species including turkeys, ducks, geese, and game birds, as well as chickens.

Notwithstanding the inaccuracies of the map, it is a matter of record that Mid Suffolk has one of the highest concentrations of intensive livestock farms and as a result has one of the worst records for ammonia pollution in the UK. More reason to carefully assess the impact that further expansion of this industry will have on the district and its surrounds and to take immediate action to fully mitigate those impacts.

The aspect of the poultry market that we have highlighted in our concerns is the intensive poultry sector (specifically broiler chicken rearing units) ie poultry holdings of more than 40,000 birds, which require an Environmental Permit to operate because of their potential to have significant impacts on the environment. The Environment Agency categorises intensive poultry units as industrial installations and in the planning system an intensive poultry development housing more than 85,000 birds falls under Schedule One of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011; the same category as a new airport or a nuclear power plant.

You pointed us to the New Anglia LEP which states that “The golden thread which runs through the Local Industrial Strategy is clean growth, with Norfolk and Suffolk positioned as the UK’s clean growth region”. The Department for Business, Energy and Industrial Strategy insists that “clean growth means growing our national income while cutting greenhouse gas emissions”. However, we must highlight again that high stocking densities in intensive poultry units result in high concentrations of organic and inorganic dust, pathogens and other micro-organisms, as well as harmful gases such as ammonia, nitrous oxide, carbon dioxide, hydrogen sulphide and methane.

1 Section 5.35 of the BMSDC Joint Local Plan Sustainability Appraisal Scoping Report states that: “The most significant source of air pollution is from transport…. the main pollutant of concern is Nitrogen Dioxide which comes from road traffic emissions.” As we have previously explained, intensive broiler sites generate significant volumes of traffic (one four shed development can generate nearly 3,000 traffic movements according to Campaign for the Protection of Rural England1, who have investigated the effects of intensive poultry developments in counties such as Shropshire, Herefordshire and Powys). Intensive poultry units also contribute to global deforestation through the heavy use of soya in poultry feed.

The Collective Statement submitted by a number of Local Parish Councils during the public consultation on the draft Joint Local Plan, raised concerns about the unrestricted growth of development within the poultry sector and identified that “there is a basic tension between the thrust for economic growth and the commitment to an environmentally sound vision for Mid Suffolk.”

Whilst the poultry industry is one component of the agri-food sector, it is also important to recognise that this sector is undergoing major change, in the form of greater scrutiny of the UK food industry, uncertainty as a result of Brexit and more recently as an outcome of the COVID-19 pandemic.

Henry Dimbleby, Independent Lead of the National Food Strategy review is clear that “Intensive farming practises have caused serious damage to the environment and the food related disease is costing the NHS billions and drastically harming the lives of millions.” Part Two of the National Food Strategy, to be published in 2021, will “examine the food system from root to branch, analysing in detail the economics and power dynamics that shape it, the benefits it brings and the harms it does. There will be much, much more on health and on the interwoven issues of climate change, biodiversity, pollution, antimicrobial resistance, zoonotic diseases and sustainable use of resources.” The Government has committed to publishing a White Paper six months after the publication of the review and it is worth noting that one of the questions that the National Food Strategy review will address is “What do we want our countryside to look like?”

The Farm Animal Investment Risk & Return (FAIRR) initiative is an investor network that aims to put factory farming on the environmental, social and governance (ESG) agenda. FAIRR ‘acts as a global collaborative network that shares research, fresh thinking and best practice with global institutional investors, policy makers, academics, NGOs and others’ and has identified factory farming as a high-risk sector for investment portfolios.

On 21st July 2020, a Nat West report2 into the outlook for the poultry sector identified that ‘prices for broilers have dropped 2.8% in the year to September 2019. Broiler production dipped slightly in the first nine months of 2019, with the number of broiler chickens slaughtered down by 3.2% to 785.6m. Reflecting the decrease, commercial broiler placings were down 1.6% in the same period to 812.7m.’ Richard Griffiths, chief executive of the British Poultry Council, comments: “Brexit uncertainty has had some impact, but rising costs of production are also playing their part. Until recently, even though costs have been increasing, production has been increasing too, so producers have been able to offset those costs somewhat. Now costs are outpacing economies of scale. Over the last 18 months we’ve seen food-price inflation too. Those squeezed incomes are affecting consumers.”

The latest DEFRA national statistics for the volume of poultry meat production (August 2020)3 record an overall 2% decline in 2019 compared to 2018 and September’s DEFRA statistics record broiler slaughterings down 4.3% whilst overall poultry meat production is down 4.2% July 2019 compared to July 2018, despite panic buying as a result of the pandemic. In a recent news report by the National Farmers’ Union (NFU) ‘Coronavirus – what is the impact on the poultry sector?’ (12 June 2020)4 the NFU acknowledges the changing situation and recognise that poultry businesses are ‘facing a changing customer base’; they are also ‘working with members to establish the financial impact the collapse of the wholesale market is having on their business’.

There is a considerable amount of research which indicates further change in the nature of consumer eating habits in the longer term but for the sake of brevity we refer to a report by the global consultancy firm, AT Kearney5, which predicts that by 2040 60% of meat consumed will be from alternative sources and not livestock.

As you note, “the changing nature of the industry…is beyond the scope of district and county councils’ control” but you should, at the very least, be aware of the changes taking place within the industry to better inform your decision-making roles in regulating the industry.

2 You comment that you are “also responsible for supporting economic growth alongside the achievement of environmental and social objectives” but it appears from communications that we have had with the Councils for the last year or so that you are intent on prioritising economic objectives over and above environmental and social objectives and we would draw your attention to the Appeal Decision (Ref: APP/W1850/W/15/3129896) by Planning Inspector Joanne Jones dated 24th December 2015 for the erection of two broiler rearing units in Hereford: “The National Planning Policy Framework promotes economic development indicating that significant weight should be placed on the need to support economic growth through the planning system. However, it sets this within the presumption in favour of sustainable development, seeking economic, social and environmental gains and indicating that they are mutually dependant. I have already concluded that there would be some social and economic gains. However, these would be at the expense of the environment as the appeal scheme would detract from the landscape character of the area and biodiversity, and it would lead to deterioration in highway safety. The appeal scheme would not, therefore, comply with the overarching aims of the Framework and it would not constitute sustainable development.”

To properly understand the economic effect of growth in intensive poultry production in the County requires a comprehensive strategic assessment and risk analysis of the impact that that growth would have on the environment, on public health, on wellbeing and amenity of communities living near the installations, on smaller scale poultry businesses, on tourism, on the landscape, on housing development, and on the desirability of Mid Suffolk as a place to live and work.

As an example, Visit (see enclosed map) illustrates that tourism in the in 2016, contributed £5.9bn to the economy, which at that time was nearly double the figure you highlight for the current contribution for the whole of the agri-food sector. Clearly the tourism market in the East of England has grown since then, now valued, according to Visit England, at more than £10bn a year, making it the largest industry sector and one of the biggest employers in the region and arguably the attraction of access to unspoilt open countryside will be one of the main drivers for future growth in this sector of the economy. The question is, what impact will creeping industrialisation in rural High Suffolk have on the ability of the local economy to capitalise on this growth?

It is our assertion that a strategic assessment including an Environmental Impact Assessment and a cost benefit analysis should have been undertaken by the Councils at the time of the enquiry for the development of a new poultry meat processing factory. The development exceeded the criteria set out in Schedule 2 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 and as such should have been screened against the criteria set out in Schedule 3 of the 2017 regulations (whether or not the site was in a sensitive area), in particular 1(b) cumulation with other existing development and/or approved development; 3 (a) the magnitude and spatial extent of the impact (for example geographical area and size of the population likely to be affected); 3 (c) the transboundary nature of the impact; 3 (g) the cumulation of the impact with the impact of other existing and/or approved development; and 3 (h) the possibility of effectively reducing the impact.

Unfortunately, it is too late to challenge the permission for the processing facility but the potential for the development to have much wider impacts was evident, which the Council failed to consider. It is not too late to take action to rectify this oversight and avoid perpetuating and compounding the problems that have arisen since.

Adopt and implement a more ‘joined up’ approach to address this issue

The minutes of the Poultry Panel meeting which took place on 22nd January 2020 did not record any actions. The Panel is not a decision-making forum; the Panel members on that date agreed its remit to include: “Panel will enable members to share knowledge and information”; and “Discussions will be of a general nature; panel members will not consider merits or otherwise of potential or existing planning applications.”

It would be very helpful to understand exactly what steps you have taken as a result of that initial meeting. Unfortunately, your letter is rather vague about the ‘reconvened and reinvigorated’ Poultry Panel, so can you please provide us with further details, including whether or not the remit has changed, who the members now are and what the outcomes of the recent meeting(s) have been?

Whilst we appreciate your intention to broaden your interaction with neighbouring authorities and regional and national bodies in order to develop a better understanding of the cumulative impact, it is, as you say, ‘unlikely to quickly address’ the points we raise.

3

We reiterate that the most pressing concern for many of the parishes in and around Eye is the impending expansion of broiler rearing sites to service the planned increase in production at the Cranswick poultry meat processing factory and the fact that current planning policy and processes have not been employed to adopt a wider assessment of the cumulative and ‘in combination effect’.

SCC and BMSDC are in a position to model this impact now: the Councils are aware that the production capacity at the vacated Weybread site was 500,000 birds a week; that the new factory is currently operating at 1.1 million birds a week, soon to reach 1.2 million birds a week; and the processing capacity of the new factory is known. Stradbroke Parish Council have suggested the methodology (Chris Edwards, SPC Chair Planning Committee email dated 5th August 2020 enclosed) to model the impact. The location of the poultry feed mill in Denham is known, as are the locations and capacity limitations of power stations and anaerobic digester sites in the area which are capable of processing waste poultry litter; more data that can be modelled now.

In view of your aim to “foster a more collaborative approach to the development of the industry … one which better understands the challenges that residents and local communities may have with this development”, we recommend that you also make arrangements with Cranswick to include visits to broiler rearing sites during the final two weeks of the rearing cycle and again during one of the cleanout days between the cycles; meetings and interviews with residents who live in close proximity to the installation would provide a clear insight into the challenges that they have with such developments.

Provide advice and take shared action to support parishes with immediate problems concerning HGV traffic

The HGV traffic numbers you quote relate only to planning application DC/20/02052 at Thorndon but you need to be clear that the traffic numbers are not substantiated, relate only to one proposed broiler rearing development and that the application in question has been ‘called in’ to the Secretary of State (in conjunction with a similar application DC/19/2195/FUL in Shadingfield, near ), in part due to the representation of traffic data.

The fact that “many of the applications that members of the public are writing to both authorities about are historical” does not mean that there is not a problem; it is a clear manifestation of the genuine and rising concerns of people within the District and should highlight to you the importance of listening to their views so as to avoid compounding problems in the future. There is growing disquiet and frustration in members of the public who feel that their concerns about increasing HGV traffic volumes are being ignored by the authorities and which led, in part, to our letter dated 6th July 2020, in order that you might become more aware of the wider, connected picture concerning HGV traffic, especially with regard to recent activity in the intensive poultry sector.

It is the cumulative impact of additional traffic generated by new planning applications for intensive poultry units, that we brought to your attention and which requires careful scrutiny, due to the high volume of HGV traffic generated by such developments. Your recognition of the need for more information on HGV movements is encouraging and we would appreciate further details of your intention in this regard.

Local Parish Councils have taken on board the comments you outlined in your letter concerning the monitoring of HGV traffic.

Include policy within the emerging Joint Local Plan to control the unrestricted growth of development within the poultry sector and set out considerations against which such development should be appraised, having regard to the wide range of impacts that intensive poultry site development generates.

We note the Councils’ intention to consider “the addition of a policy in the Joint Local Plan to address agricultural buildings” but bring to your attention the fact that the definition of agriculture is set out in s.336 of the Town and Country Planning Act (TCPA) 1990 as follows: “agriculture” includes horticulture, fruit growing, seed growing, dairy farming, the breeding and keeping of livestock (including any creature kept for the production of food, wool, skins or fur, or for the purpose of its use in the farming of land), the use of land as grazing land, meadow land, osier land, market gardens and nursery grounds, and the use of land for woodlands where that use is ancillary to the farming of land for other agricultural purposes, and “agricultural” shall be construed accordingly;”

Intensive poultry units currently fall within the TCPA definition of agriculture (the keeping of livestock for the production of food), despite the fact that such units are industrial in terms of design, scale and impact. Development in the open countryside is restricted through planning policies and by defining settlement boundaries and/or identifying specific locations for development but intensive livestock units and other agricultural development are not subject to these constraints.

4 We would draw your attention to Appeal Decision (Ref: APP/W1850/W/15/3129896) again, by Planning Inspector Joanne Jones dated 24th December 2015 for the erection of two broiler rearing units in Hereford: “The proposed broiler units, although designed for the production of food and generally regarded as an agricultural operation, would be industrial in scale. The sheds would be lower than the adjacent open sided cattle sheds; however, there is no doubt that the scale of buildings would make them significant built structures within the farmland landscape.”

Unfortunately, your proposal to consider the removal of ‘certain permitted development rights’ will do little to address the issues we have raised because permitted developments represent a minority of cases. An agricultural building of 1,000m2 will only house up to 20,000 birds (see the agent’s latest correspondence on DC/19/2195/FUL Shadingfield) and whilst clearly capable of contributing to the cumulative effect within the district, it represents a relatively minor development within the scheme of the industry.

The industry has upscaled significantly from buildings the length of tennis courts to buildings the length of football pitches - the size of buildings proposed in recent planning applications for intensive poultry units is typically 2,300m2, housing up to 50,000 birds in one shed. A four shed development can produce almost 1.5m birds in one year and will generate thousands of annual traffic movements (see reference earlier) and by comparison will produce as many birds in 5 weeks as a building with permitted development rights can produce in one year, which clearly has a far greater incremental impact.

Herefordshire Campaign for the Protection of Rural England is one organisation lobbying for a change in planning policy to recognise that intensive livestock units are industrial development, with impacts as harmful as other large industries, that should be located on brownfield land with good transport connections, located far from people’s homes and on sites where the landscape will not be harmed. There are many others calling for changes in planning policy and research into the public health risks of intensive poultry units.

Develop a mitigation plan to prevent overconcentration and intensification of poultry units in inappropriate rural locations.

The government’s National Food Strategy states; ‘The food system is riddled with negative externalities: polluted water and air, greenhouse gas emissions, antibiotic resistance, biodiversity loss, even the cost of diabetes treatments.” Suffolk already has a dense concentration of intensive livestock operations that result in negative externalities such as those illustrated above and more.

By approving yet more intensive poultry units, which individually house far greater concentrations of birds than ever before, the Council will steadily add to already mounting environmental and public health problems and undermine its emergency climate commitment, its plans for sustainable housing development, its plans for tourism and economic development in other sectors. If that is not enough, then many Parish Councils have pointed out in the Collective Statement in response to the draft Joint Local Plan, overconcentration of this type of development also “has the very real potential to give rise to substantial and adverse transformation of the valued landscape and the visual environment of rural Suffolk.”

If not the Councils, who says “enough is enough?”

Implement a rigorous appraisal of planning applications in relation to poultry site developments and consider such applications within the wider context of existing poultry sites and the cumulative effect in terms of pollution, HGV traffic increase, Health and wellbeing and the loss of community amenity and harm to the environment and landscape.

We draw your attention to planning application DC/20/03174 (Removal of 2no existing poultry buildings, and erection of 2no new poultry houses with connecting store area. Moving of gas tanks, installation of new underground dirty water tanks and new areas of concrete hardstanding) which was received by BMSDC on 29th July 2020. This is an existing intensive poultry rearing site growing broilers for processing at the Cranswick meat processing factory at Eye Airfield. The Design and Access Statement is the most ambiguous we have seen to date (having researched nearly 150 planning applications and scoping enquiries for poultry site developments in Mid Suffolk, East Suffolk, South Norfolk and Breckland, besides many others elsewhere in the UK) and requires close attention to detail in order to understand the proposal; it gives no particulars of the number of additional birds to be housed on the premises. The site is already a large intensive poultry unit (with an Environmental Permit6 to house 250,000 birds) and the replacement buildings will result in an additional 1,103m gross internal floorspace, which is twice the trigger threshold for EIA screening set out in Schedule 2 and yet there is nothing on the planning portal to indicate that EIA screening was considered at the registration stage.

5 This application will result in additional HGV traffic in Denham (where the mill is located) as well as Hoxne and Stradbroke on routes to and from the mill. No consideration has been given to the cumulative impact of HGV traffic or the additional waste that will be generated from the site – 32,000 extra birds will create hundreds of tonnes of additional poultry litter waste – where will it be disposed of? The outcome of Squire v Shropshire Council7 Court of Appeal case puts the onus on the Councils to take responsibility to address this and other questions regarding waste and pollutants from an expanding intensive poultry unit.

The Councils must employ tighter scrutiny and ensure (Metfield case in point) more rigorous appraisal to achieve greater transparency in planning applications for intensive poultry units. In this regard, the Councils must seek independent intelligence, clarification and full disclosure as the basis for sound decision making.

Currently, there are three parallel planning applications for intensive poultry units – all with the same purpose to supply the same company and it appears highly likely that a fourth (the proposal to expand the capacity of Barley Brigg anaerobic biodigester and the adjacent drying barn) is part of the same programme of development. We urge the Councils to implement appraisals of these and future planning applications for intensive poultry units within the context of the cumulative and ‘in combination’ effect, for all of the reasons outlined in this letter.

Summary

We feel that the actions summarised in your letter dated 3rd August 2020 do not go far enough to address our concerns and propose the following:

• Provide further details of the Poultry Panel, including whether or not the remit has changed, who the members now are and what the outcomes of the recent meeting(s) have been. • Model the impact of the Cranswick meat processing factory and its network of intensive poultry units as a matter of urgency. • Bring forward the public consultation on the HGV Review initiative. • Draft a policy for inclusion in the Joint Local Plan that recognises intensive poultry units as industrial development, with impacts as harmful as other large industries, providing guidance designed to direct intensive poultry units to appropriate locations to ensure that harmful impacts are fully mitigated. • Employ tighter scrutiny and ensure more rigorous appraisal to achieve greater transparency and full disclosure in planning applications for intensive poultry units. • Appraise planning applications for intensive poultry units within the context of the cumulative and ‘in combination’ effect. • Conduct a comprehensive strategic assessment and risk analysis, to quantify the externalities, especially with regard to the impact that the growth of intensive poultry units will have on the environment, on public health, on wellbeing and amenity of communities, on smaller scale poultry businesses, on tourism, on the landscape, on housing development, and on the desirability of Mid Suffolk as a place to live and work.

Can you please consider our proposals and inform us of your intentions?

Yours sincerely,

Elizabeth Gibson-Harries Jill Erben Chair, Horham & Athelington Parish Council Clerk to Southolt Parish Meeting

Sue Ives Campaign Coordinator, Save Our Suffolk Countryside

(Unsigned due to Covid 19 restrictions)

6

CC:

Cllr Suzie Morley (Leader Mid Suffolk District Council) Cllr Matthew Hicks (Leader Suffolk County Council) Fiona Duhamel (Assistant Director Economic Development & Regeneration BMSDC) Philip Isbell (Chief Planning Officer BMSDC) Cllr Andrew Reid (Member for Highways, Transport and Rural Affairs) Cllr Louis Busuttil (Deputy Cabinet Member for Highways Strategy) Cllr Julie Flatman Cllr Peter Gould Cllr Guy McGregor Cllr Andrew Stringer

Denham Parish Clerk Eye Town Council Town Clerk Hoxne Parish Clerk Redlingfield Parish Clerk Rishangles Parish Meeting Stradbroke Parish Clerk Thorndon Parish Clerk Wilby Parish Clerk Parish Clerk

(1) A charity in England with over 40,000 members and supporters that campaigns for a sustainable future for the English countryside (2) https://natwestbusinesshub.com/articles/agriculture-outlook-the-poultry-sector (3) https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/913697/poul try-statsnotice-01sep20.pdf (4) https://www.nfuonline.com/news/coronavirus-updates-and-advice/coronavirus-news/coronavirus-what-is-the- impact-on-the-poultry-sector/#Demand%20for%20poultry%20products (5) https://www.kearney.com/documents/20152/2795757/How+Will+Cultured+Meat+and+Meat+Alternatives+Disru pt+the+Agricultural+and+Food+Industry.pdf/06ec385b-63a1-71d2-c081-51c07ab88ad1?t=1559860712714 (6) FOI - Number PP3933UR (7) The case of R (Squire) v Shropshire Council [2019] EWCA Civ 888

7