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Horham and Southolt Parishes Save Our Suffolk Countryside (See Contact Details Below)

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Horham and Southolt Parishes Save Our Suffolk Countryside (See Contact Details Below) Horham and Southolt Parishes Save Our Suffolk Countryside (see contact details below) Nicola Beach Chief Executive Suffolk County Council Arthur Charvonia Chief Executive Babergh & Mid Suffolk District Council Endeavour House 8 Russell Road Ipswich 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.
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