Planning Application for Cattle Accommodation Building at Langdon Mill Farm, , , , SA68 0NJ

Supporting Statement/Policy Appraisal

June 2013

Reading Agricultural Consultants Beechwood Court, Long Toll, Woodcote RG8 0RR

Tel: 01491 684233

www.readingagricultural.co.uk Introduction 1. Hugh and David James of M D James and Sons (the Applicants) has instructed Reading Agricultural Consultants Ltd (RAC) to submit a planning application for a cattle accommodation building at Langdon Mill Farm, Jeffreyston, Kilgetty, Pembrokeshire, SA68 0NJ.

2. This statement sets out an assessment of the need for the new development in terms of the expansion and modernisation of the farm unit, and considers the development in the light of relevant Development Plan Policies and National Planning Guidance.

Background

3. Langdon Mill Farm is a dairy unit extending to approximately 876ha, comprising 231ha owned land (The farm has recently agreed to purchase of an additional 90ha near Village) and 645ha rented, located approximately 1km north of the village of Jeffreyston. The holding currently has a herd of 950 cows, which are housed indoors for the majority of the year in cubicle accommodation and grazed outdoors when weather and soil conditions permit.

4. There has been significant investment in buildings and infrastructure at the farm in recent years, with the farm moving away from beef, lamb and arable production to concentrate solely on producing milk.

5. The unit is extremely efficient achieving yields of more than 10,000 litres/cow/year, with cows being milked three times/day in the 60‐point rotary parlour. The majority of the herd is housed in cubicle accommodation with facilities for in‐calf heifers, new calves and sick animals. Replacement rates at the farm are currently 25%, the culling rate having improved as a direct result of the new facilities. The new buildings include a feed storage shed which also greatly improves the operation of the unit and meets the requirements of the Feed Hygiene () Regulations (2006).

6. Although the unit bought in a number of heifers during the recent expansion, the farm now breeds its own replacements due to the ongoing threat of bovine TB. The farm has recently had movement restrictions imposed on it due to bovine TB, and as a result now includes TB isolation facilities.

7. The farm currently employs 12 full‐time staff (including the Applicant and his brother) and five part‐time staff. Of these, four (including the Applicant) live on site in the two dwellings opposite the farm, with the remaining staff living in the locality.

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Planning Policy

8. National planning policy guidance on agricultural development is set out in PPW Chapter 7 ‘Supporting the Economy' (2011), which considers a “flexible and efficient agricultural industry” be essential.

9. This supportive stance is expanded in paragraph 7.6.6 which states that:

“Local planning authorities should adopt a constructive approach towards agricultural development proposals, especially those which are designed to meet the needs of changing farming practices, or are necessary to achieve compliance with new environmental, hygiene or welfare legislation.”

10. Additional planning guidance is set out in TAN 6 ‘Planning for Sustainable Rural Communities’ (2010), whose objective is to promote a: “sustainable and profitable future for farming…. while safeguarding the environment, animal health and welfare….”

11. Local planning policy can be found within the Pembrokeshire County Council Local Development Plan (LDP) (Adopted 2013). Although the plan does not have any policies which relate specifically to agricultural buildings, it does have polices which are relevant to the proposal.

12. Policy SP1 (Sustainable Development ) must be applied to all development proposals and requires that:

“All development proposals must demonstrate how positive economic, social and environmental impacts will be achieved and adverse impacts minimised.”

13. Another of the LDP policies which is relevant to all development proposals is GN.1 (General Development Policy) which states that:

“Development will be permitted where the following criteria are met:

1. The nature, location, siting and scale of the proposed development is compatible with the capacity and character of the site and the area within which it is located;

2. It would not result in a significant detrimental impact on local amenity in terms of visual impact, loss of light or privacy, odours, smoke, fumes, dust, air quality or an increase in noise or vibration levels;

3. It would not adversely affect landscape character, quality or diversity, including the special qualities of the Pembrokeshire Coast National Park and neighbouring authorities;

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4. It respects and protects the natural environment including protected habitats and species;

5. It would take place in an accessible location, would incorporate sustainable transport and accessibility principles and would not result in a detrimental impact on highway safety or in traffic exceeding the capacity of the highway network;

6. Necessary and appropriate service infrastructure, access and parking can be provided;…

… 8. It would not have a significant adverse impact on water quality; …”

14. Due to the potential for an increase in run‐off at the site, it is necessary to assess the application against policy GN.2 (Sustainable Design).

“Development will be permitted where relevant criteria are met:…

…3. It incorporates a resource efficient and climate responsive design through location, orientation, density, layout, land use, materials, water conservation and the use of sustainable drainage systems and waste management solutions;…”

15. Although there are no designated nature conservation sites in close proximity to the development site, the proposed development has the potential to impact on the Pembrokeshire Marine Special Area of Conservation (SAC) through accidental run‐off from slurry spreading operations. In addition, the proximity of the new buildings to a hedgerow and watercourse also has the potential to impact on local wildlife. As such it is deemed appropriate to appraise the application against GN.37 (Protection and Enhancement of Biodiversity)

“All development should demonstrate a positive approach to maintaining and, wherever possible, enhancing biodiversity. Development that would disturb or otherwise harm protected species or their habitats, or the integrity of other habitats, sites or features of importance to wildlife and individual species, will only be permitted in exceptional circumstances where the effects are minimised or mitigated through careful design, work scheduling or other appropriate measures.”

Policy Appraisal

16. The following policy appraisal addresses seven key questions:

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i. does the building subject of this application “… meet the needs of changing farming practices, or are necessary to achieve compliance with new environmental, hygiene or welfare legislation.”?

ii. are there positive economic, social and environmental impacts associated with the new development, and are any adverse impacts mitigated?

iii. would the new building increase the risk of flooding elsewhere?

iv. does the new building adversely impact on the local landscape?

v. does the new building and the associated operation adversely affect local amenity?

vi. does the new development have an impact on local ecology or any ecologically designated sites?

vii. are there any significant highways impacts associated with the proposed development?

General Policy

17. The proposed development is in line with the general tenor of national planning policy and guidance as it forms part of a programme of measures to improve welfare and facilities at Langdon Mill Farm as well as allowing for a natural expansion.

18. In terms of welfare facilities, the application includes facilities for in‐calf heifers (Building 1), newly born calves and sick cows (Building 3). The application also seeks planning permission to extend the TB isolation facilities (Building 2).

19. The overall expansion of the herd is also in line with national industry trends in that there is a need to increase the size of dairy units for producers to remain competitive in both national and international markets. With an estimated three dairy farmers leaving the industry every week and British milk production now near its lowest level since the 1970s, ever‐increasing quantities of milk products are imported to the UK. The building is designed and located to meet the economic and environmental challenges raised by the need to increase productivity and to provide people with a safe, healthy and affordable locally/home produced food product that does not compromise the natural resources on which future food production depends.

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20. As such, the proposal is fully in line with national planning policy and guidance in that it will enable the farm to be “flexible and efficient” as well as by allowing the unit to “safeguard... animal health and welfare”.

Sustainable Development

21. In terms of the sustainable development, the recent expansion of the dairy unit at Langdon Mill Farm has seen a rise in employment at the farm from five full‐time and one part‐time five years ago, to the current number of 12 full‐time and five part‐time employees. The proposed expansion of the herd is expected to generate an additional three full‐time and three part‐time jobs at the site. The on‐going and planned future success of the dairy unit demonstrates a clear positive economic and social impact to the locality through providing vibrant and economically sustainable rural communities. As such it is considered that the application is broadly in line Policy SP.1 of the LDP. Any potential adverse impacts on the environment and associated mitigation are discussed below.

Flood Risk

22. The construction of large areas of impermeable surfaces has the potential to raise flood risk elsewhere through increased run‐off. The large area of new roofing proposed as part of the scheme has an obvious potential to increase flood risk, and as such associated run‐off will have to be dealt with appropriately. No other hard surfaces are proposed as part of the development.

23. The total rainwater runoff from the roof of the new building has been calculated, with results provided in Appendix 1.

24. All run‐off from the roof of the new building will be collected and discharged into a balancing pond proposed as part of planning application (Ref: 13/0001/PA). This is located adjacent to the west of the development site (see Figure RAC/5828/5). From here it will be discharged into the adjacent watercourse at a rate of no more than 2 litres/second, controlled by a hydraulic brake. The new development would therefore mitigate the potential for increased flooding downstream from the site, and ensure that the application meets the requirements of local plan policy GN.2.

Landscape

25. Despite the large size of the new building, its position directly adjacent to existing buildings, and the unit’s location in the bottom of a valley ensures that the number of

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potential near and distant viewpoints into the site is limited. Apart from the un‐named highway running between the A477 and the B4586 (Ford Lane), and intermittent views from Ford Lane itself, views from public highways are restricted by tall, established hedgerows and trees. The principal viewpoint of the new buildings is from the nearby junction of the unnamed road and Ford Lane. This view of the site, which shows a ‘worst case’ example is shown in Appendix 2 ‐ Photograph 4. Other views into the site from nearby vantage points are also provided in Appendix 2.

26. Although the new building would be partially screened by existing vegetation, it is proposed to include a number of soft landscaping measures to mitigate the impact of the new buildings on the landscape. Details of the planting are included in the landscaping scheme in the accompanying Design and Access Statement.

27. Due to the large number of intervening hedgerows and trees the application site is not visible from the only Public Right‐of‐Way in the locality, which runs between Langdon Farm and Jeffreyston.

28. The building will be constructed using similar materials to those found on the rest of the farm unit and are typical of those found in an agricultural landscape.

29. Lighting associated within the building is downward facing and located above eaves level to prevent spill or direct views of luminaires. The level of lighting has been restricted to the minimum necessary for the operation of the unit. No external lighting would be installed as a result of the new development.

30. As such, it is not considered that the building subject of this application would have any significant impact on the local countryside, with the proposed landscaping measures significantly improving views of the new and existing farm unit. Therefore the application is considered to be fully in line with criteria 1 and 3 of LDP policy GN.1.

Local Amenity

31. The effects on public amenity normally associated with dairy farms are related to odour, noise and dust. The nearest sensitive receptor to the buildings subject of this application is located approximately 400m to the north‐west of the unit. There is another dwelling located 320m to the north of the new buildings however this is associated with the adjacent livestock farm (Corner Park Farm) and as such has a reduced sensitivity. It is also important to consider the position of the farm: in a rural location with a history of dairy farming.

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32. Impacts on local amenity related to odour, noise and dust would be limited due to a combination of distance, prevailing wind direction (south‐westerly) and historic farming practices in the locality. In addition, noise from cows would be reduced as the level of noise arising from the animals relates directly to welfare, with noise only arising from distressed animals. As the proposed building would be constructed in line with the RSPCA welfare guidance1, it is unlikely that the new buildings will bring about an increase in associated noise.

33. The increased herd size which would be associated with the new building will also bring about a direct increase in the volume of slurry which needs to be applied to land. Although the application to land of slurry has the potential to give rise to loss of amenity, the umbilical‐fed and tanker‐mounted trailing shoe spreading equipment which is in use at the farm ensures that odours associated with slurry spreading operations are kept to a minimum. In addition, heaps of solid material arising from dairy farming operations are, and will not be located within 200 metres of any potentially affected property. The farm has two recently‐constructed slurry lagoons (Ref: 12/0014/PA and 12/0016/PA) in the locality (see Figure RAC/5828/7) which provide adequate off‐site storage of slurry arising from the unit. This also minimises the number odour sources at Langdon Mill Farm.

34. It is considered therefore that due to the separation distance, the history of dairy farming in the area and spreading equipment all ensure that any increase in odour associated with the new cattle accommodation would not impact on the amenity of nearby receptors by way of air pollution, dust or noise. It is therefore considered that the buildings subject of this application meet the requirements of criterion 2 of LDP policy GN.1.

Ecology

35. The nearest ecologically designated sites to the farm unit are Jeffreyston Pastures Site of Special Scientific Interest (SSSI) approximately 1.5km south of the farm and Sir Benfro SSSI approximately 3.2km to the north. It is not considered that either of these sites would be significantly affected by the buildings or operations subject of this application.

36. However, the Pembrokeshire Marine Special Area of Conservation (SAC) lies 3.7km west of the new buildings and has the potential to be affected by accidental run‐off from the

1 RSPCA welfare standards for dairy cattle, June 2011

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site and associated slurry spreading operations. The farm currently uses approximately 876ha for slurry spreading which far exceeds the minimum 345ha necessary for the size of the herd at the holding2. The farm also has adequate land to spread slurry at the lower rate of 170kgN/ha as required by the Nitrate Pollution Prevention Regulations (Wales) 2008 (NVZ) , which do not currently apply at this site. The extent and location of this spreading area is shown on Figure RAC/5828/73. All slurry is spread in accordance with the NVZ regulations, with the newly constructed slurry lagoons (Ref: 12/0014/PA and 12/0016/PA) providing enough storage for 17,300m3. Combined with the existing 1,140m3 slurry tower at the farm, there is capacity for more than four months slurry storage available at the farm.

37. All of the internal hardstanding areas would be laid to falls which drain towards slurry channels which have been designed, specified to conform to British Standard 5502. All of the slurry storage facilities at the site have been constructed in line with The Water Resources (Control of Pollution) (Silage, Slurry and Agricultural Fuel Oil) (Wales) Regulations 2010 (SSAFO).

38. Due to the large area of land available for slurry spreading, the availability of slurry storage to meet the needs of SSAFO, and the construction of slurry handling facilities which meet the requirements of BS5502 and SSAFO, it not considered that the proposed development or farm holding as a whole has any adverse impact on the Pembrokeshire Marine SAC.

39. As such it is considered that the application meets the requirements of local planning policies GN.1 (criteria a,4 and 8) and GN.37.

Highways

40. As the proposed building would provide for an additional 328 cow places (allowing for the empty cubicles), there would be an associated increase in traffic movements to and from the farm. The change in traffic movements brought about by the new building has been calculated and is provided in the accompanying Design and Access Statement. The calculations demonstrate that at the proposed stocking rates, the proposed building would bring about an overall increase of 2,703 movements per year. However, of these

2 Assuming the total N content of organic manures and maximum application rates to supply 250 kg N/ha of total nitrogen ‐ Guidance for Farmers in Nitrate Vulnerable Zones Standard values, manure sampling protocol and glossary (Defra – 2009). 3 Newly purchased land at Cosheston Village not shown.

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movements, the vast majority are car movements associated with the increase in workers at the farm rather than HGV or tractor‐trailer movements. The figures do not make any allowance for workers sharing vehicles or walking/cycling to work and as such show a worst case scenario. Other associated movements such as vets, foot trimming and deliveries have not increased due to the expansion because visitors undertaking specific jobs simply remain on farm for longer periods.

41. The number of HGV movements has seen an increase by 284 movements/year or less than one vehicle every two days (one vehicle producing two movements). HGVs access the national road network by using a 2.5km stretch of the B4586 to reach the A4075, minimising the use of narrow lanes and avoiding any built up areas.

42. Other traffic movements associated with the increase in herd size relate to tractor and trailers collecting forage and spreading slurry. The construction of the off‐site slurry stores, which are filled using overland pipelines, and the extensive network of farm tracks (as shown on Figure RAC/5828/7) has reduced the potential increase in traffic movements, although there would still be an increase of 338 movements associated with this vehicle class.

43. The farm already has suitable entrance providing good visibility in both directions. The associated track is subject of application Ref: 13/0001/PA.

44. Although the construction and operation of the proposed building would bring about a significant increase in traffic movements, the vast majority of these relate to car movements and are considered a worst case scenario. There would be an increase in the number of tractor and trailer movements and HGV movements, but the frequency of these movements and the easy access to the national road network ensure that the increase in these vehicle types would not have a significant impact on the locality. As such it is considered that the proposal is in accordance with criteria 5 and 6 of local plan policy GN.1.

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Conclusions

45. In the light of the foregoing appraisal, it is concluded that:

(i) the development is fully in line with the tenor of national planning guidance which promotes a “sustainable and profitable future for farming”;

(ii) the increase in the size of the dairy herd and concentration on dairy production at the farm is in response to the industry trend for larger, specialised units, which are necessary for producers to remain competitive in current national and international marketplaces;

(iii) the proposed building has been designed to high welfare standards;

(iv) three full‐time and three part‐time jobs would be generated by the new development, providing clear economic and social benefits;

(v) The provision of a new balancing pond with hydraulic brake associated with planning application 13/0001/PA will ensure that that run‐off from the new development will not increase the risk of flooding;

(vi) The location of the new building at the bottom of a valley and adjacent to the existing farmyard, combined with the limited viewpoints into the site would minimise of the impact of the development on the landscape. The existing trees and hedgerows combined with the proposed landscaping scheme would further reduce any effect on the local countryside;

(vii) the separation distance between the farm and nearest sensitive receptor ensures that that the odour, dust and noise associated with the unit would not affect public amenity;

(viii) There are no ecologically designated sites in the vicinity of the new development. The farm has ample slurry storage and spreading land minimising the impact on the Pembrokeshire Marine SAC from nutrient rich run‐off.

(ix) There are no significant highways impacts associated with the recent expansion of the farm, as although there would be a 21% increase in vehicle movements, the vast majority of these would be car movements associated with the increase in employment. There would increases in HGV and tractor

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and trailer movements, but it is not considered that these would be large enough to have a significant effect on the local highway network.

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APPENDIX 1: Surface Water Discharge Calculations 1. The volume of storage required to reduce surface water run‐off from new impermeable surfaces to that of the site prior to development (green field) has been calculated4. The results of these calculations are provided in Appendix A.

2. The storage volume required prevent increased flooding downstream caused by the development is provided by the long term storage figure. This is described as follows:

Long term storage (m3)

3. Long term storage is similar to attenuation storage, but aims to specifically address the additional volume of runoff caused by the development compared to pre‐development runoff. Long term storage is specifically aimed at runoff during extreme events to limit flood impact downstream.

4. This volume difference should be infiltrated to the ground or, if this is not possible, discharged to the receiving water at very low flow rates (less than 2 l/s/ha) so as to minimise the risk of exacerbating river flooding. In this situation, the normal attenuation discharge limit should be adjusted (reduced) to take account of any discharge rate taking place from the Long Term Storage system.

5. Long term storage is calculated based on the difference between greenfield and development runoff volumes based on the 100 year 6 hours rainfall event. This is a pragmatic solution and avoids the need for complex analysis of extreme rainfall series.

6. A 1.3 climate change allowance factor has been included in the calculations.

Method of Surface Water Disposal

7. Rainfall incident to the roof area, less a negligible small evaporative loss will flow to guttering which will then discharge into a balancing pond (subject of planning application Ref: 13/0001/PA) with a volume of approximately 440m3, which will be located to the west of the site (see Figure RAC/5828/5). From here it will flow into the adjacent stream at a rate of less than 2 l/s. In order to achieve these very low flow rates, a hydraulic brake mechanism, such as that shown in Appendix A, will be installed.

8. The balancing pond would measure approximately 21m by 21m and would be 1.3m deep. With a usable storage depth of 1m. The usable storage volume of the pond would be approximately 320m3. This is well in excess of the 200m3 required for long‐ term storage of run‐off from the recently constructed buildings and the additional 72m2

4 Using tool provided by HR Wallingford: http://geoservergisweb2.hrwallingford.co.uk/uksd/surfacewaterstorage.aspx

required for the for the proposed building. This design of pond will establish an area with high biodiversity value taking the form of a permanent wetland with small areas of standing water, subject to periodic flooding.

Appendix A ‐ Surface Water Storage Requirements for Sites

Site name: Langdon Mill New Building Site location: Jefferyston Site coordinates Latitude: 51.73438 deg N Longitude: 4.77492 deg W Reference: 1369823998400 Date: 29/5/2013

This is an estimation of the storage volume requirements that are needed to meet normal best practice criteria in line with Environment Agency guidance "Preliminary rainfall runoff management for developments" (2005), W5‐074/A/TR1/1 rev. D and the CIRIA SUDS Manual (2007). It is not to be used for detailed design of drainage systems. It is recommended that detailed design of any drainage scheme uses hydraulic modelling software to finalise storage requirements before construction takes place.

Site Characteristics: Total site area 0.2911 ha Significant public open space ha Area positively drained 0.29 ha Impermeable area 0.29 ha Percentage of drained area that is impermeable 100 % Impervious area drained via infiltration 0 ha Return period for infiltration system design 10 year Impervious area drained to rainwater harvesting systems 0 ha Return period for rainwater harvesting system design 10 year Compliance factor for rainwater harvesting system design 70 % Net site area for storage volume design 0.29 ha

Methodology: Greenfield runoff method IH 124 Volume control approach Long Term Storage

Automatic values Editable values Hydrological Characteristics: HOST 24 24 SPRHOST 0.397 0.397 SAAR 1180 1180 mm M5‐60 Rainfall Depth 17 17 mm 'r' Ratio M5‐60/M5‐2 day 0.3 0.3 FEH/FSR conversion factor 0.79 0.79 Hydrological region 9 9 Growth curve factor: 1 year 0.88 0.88 Growth curve factor: 30 year 1.78 1.78 Growth curve factor: 100 year 2.18 2.18

Design Criteria: Climate change allowance factor 1.3 1.3 Urban creep allowance factor 1.1 1.1 Interception rainfall depth 5 5 mm

Greenfield Runoff Rates: Qbar 1.79 1.79 l/s 1 in 1 year 5 5 l/s 1 in 30 years 5 5 l/s 1 in 100 years 5 5 l/s

Estimated Storage Volumes: Interception storage 11.6 11.6 m3 Attenuation storage 190.13 190.13 m3 Long term storage 71.29 71.29 m3 Treatment storage 34.8 34.8 m3 Total storage 273.02 273.02 m3

Please note that a minimum flow of 5 l/s applies to any site HR Wallingford Ltd, the Environment Agency and any local authority are not liable for the performance of a drainage scheme which is based upon the output of this report.

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Turning Water Around...® APPENDIX 2: Photographs of Development Site from Viewpoints in the Locality

Position of new building

Photograph 1: View into development site from un‐named road between B4586 and

Position of new building

Photograph 2: View into farm from B4586 heading south. Buildings shown do not form part of application.

Position of new building

Photograph 3: View into farm from B4586 heading north

Photograph 4: View of development site from B4586 bridge to west. Location of balancing pond and landscaping block A.