The proposed IPU at Frochas Farm is going to have a significant impact on the environment from the way it deals with manure produced by one million chickens a year through to how it will prevent pollutants from entering streams and brooks.
In addition to this, IPUs release huge amounts of ammonia, nauseating odours and other pollutants into the air – since this pollution is airborne it can blow into the centre of Welshpool that will make it unpleasant and a health risk.
There are more than 30 residences and families living within 500 metres of this proposed development, and hundreds within a one mile radius of the site and secondary manure dumping site near Windmill Lane (close to Red Bank). This will also impact Sainsbury’s, Welshpool High School and Salop Road.
On this ground alone this proposal should be rejected.
The manure disposal management system contained in the Environment Assessment (EA) is inadequate. It offers a range of possibilities including field storage, land spreading either on site or elsewhere, on site covered storage or removal to an off site anaerobic digester.
The location of “other land under the control of the proposer” for storage / spreading is also close to Welshpool (a site near Windmill Lane has been mentioned), further adding to the pollution concerns.
What is certain is that manure will be generated by the IPU on an industrial scale.
There is no mention in the EA of the capacity of the farm manure store or of the quantities of manure produced by existing cattle and sheep.
The EA refers to an annual manure production from the IPU of 2,169 tonnes. Based on DEFRA estimates of 1.5 tonnes of excreta per month per 1,000 birds, with an average residence time in the IPU of 38 days per cycle for 150,000 birds and a total of 7.6 crop cycles per year, the figure of 2,169 tonnes per annum appears to be fair estimate.
When the sheds are cleared at the end of each cycle, in addition to manure there will be 12 tonnes of contaminated spent bedding (based on the EA estimate of 1.72 Kg of bedding per square metre within the IPU). In addition to the farm’s existing manure production, there will be a requirement to safely dispose of a further 297 tonnes of manure and spent litter every six weeks.
Clearly there is insufficient area available at the farm to safely spread such large quantities of high nitrogen content manure.
In view of the sloping profile of most of the farm, any use of field storage will also carry a risk of nitrate pollution to land and watercourses.
It becomes more apparent that large amounts of manure will need to be moved off site for safe disposal leading to a substantial increase in HGV movements along the local service road at the end of each six weekly cycle. The actual location of alternative sites for spreading are also close to Welshpool and but no consideration has been given to the effects of pollutants on the local environment or people living nearby.
The issue of using large quantities of antibiotics in broiler feed and the associated risks to human health and the environment demands thorough investigation, particularly the environmental effects of antibiotics in the manure to be spread on fields under the applicant’s control. The manure management plans that accompany this planning application are inadequate in the light of, the Welsh Government Planning Directorate’s guidance to LPAs dated June 2018 and NRW’s updated guidance on polluting emissions, ammonia, dust, odour, nutrients, manure and effluents.
Nitrogen and Ammonia Pollution
DEFRA estimates that airborne ammonia production from within IPUs is 0.034kg per animal place per year. The upper limit set by NRW is 0.08kg. Both figures assume regular removal of manure from units by a conveyor system. The application’s EA infers a single total clearance at the end of the cycle. The latter method runs the risk of higher emissions that would peak when the units are opened and the birds are removed in weeks 5 and 6 of the crop cycle.
Airborne ammonia will be extracted through roof fans into the local atmosphere. Using the DEFRA estimates above, and an average bird residency time of 38 days per crop cycle and 7.6 cycles per annum, the 150,000 broiler IPU will emit 4.04 tonnes of ammonia pollution per year. This may not be a worst case dependent on the operating procedures within the units.
In addition to its noxious odour and ill effects on older people with respiratory problems, high emissions of ammonia are a threat to plants, mosses, lichens and the wealth of wildlife they support.
Field spreading of manure/spent bedding will also give rise to ammonia emissions. The Environmental Agency/Misselbrook estimate that 0.9% of the tonnage spread is emitted to the atmosphere as ammonia.
If as little as 40% of the annual manure tonnage of 2,169 produced by the IPU was spread on fields, either owned or rented, a further 7.8 tonnes of ammonia would be emitted.
Large quantities of ammonia are being released without an accurate understanding of its effects on the health of people living in the locality.
Gaseous ammonia (NH3) is the most abundant alkaline gas in the atmosphere. In addition, it is a major component of total reactive nitrogen. The largest source of NH3 emissions is agriculture, including animal husbandry and NH3-based fertiliser applications. This is a concern because NH3 plays a significant role in the formation of atmospheric particulate matter, visibility degradation and atmospheric deposition of nitrogen to sensitive ecosystems. Thus, the increase in NH3 emissions negatively influences environmental and public health as well as climate change. For these reasons, it is important to have a clear understanding of the sources, deposition and atmospheric behaviour of NH3.
The Welsh Government’s recent guidance to LPAs identifies this as an issue requiring better assessment.
Atmospheric Dispersion and Deposition Forecasts
The forecasts put forward in support of the application are based on models of ammonia, odour and dust generated in the IPU being emitted to the local atmosphere through roof extraction fans.
The emission model data is then input into a dispersion model that tries to forecast the spread of pollutants within a specific area, based on a statistical interpretation of local topography and other factors.
There are no actual measurements of emitted pollutants from other similar sized IPUs to validate the accuracy of the modelled forecasts.
The forecasts produced openly recognise that a local population may be exposed to short-term pollution that is above the forecast average but then fails to define ‘short-term’ or the magnitude of the increase.
The forecasts produced for dispersion of pollutants by wind are based on average metrological data and are limited to a maximum wind speed of 26mph. No account is taken of the effects of more extreme weather events. The area around the IPU site is frequently exposed to westerly and northerly winds of over 40mph. There is an obvious risk that higher wind speeds would spread pollutants across a wider area, including Welshpool residential areas as well Powys Castle and other tourist and visitor attractions.
The modelled forecasts predict pollution by ammonia at Gungrog (a residential area in Welshpool) at a level above the lower limit set by NRW. There is no mention of pollution levels at other nearby locations, Welshpool Hospital, for example.
Anhydrous ammonia is slightly lighter than air and will disperse into the atmosphere. In certain humid conditions hydrated ammonia can be formed which is heavier than air. Critically, the modelling fails to distinguish between the two and their individual dispersion and deposition profiles. There is a concern that the latter will disperse and deposit over a shorter range but at higher concentrations.
Bron y Buckly Wood, a Site of Special Scientific Interest (SSSI), is 0.7 miles from the proposed IPU. The health and well-being of the families living in the adjacent Bron y Buckly residential area of Welshpool is of even greater concern when considering exposure to continuous dispersion/deposition of ammonia and contaminated dust.
The modelling used is a desktop exercise in statistical interpretation and predictions. Its data inputs are based on averages and its outputs are far from conclusive. Its conclusions are at best, guesstimates with no validation.
The proximity of this proposed IPU to areas of residential population demands a better, independent assessment of pollution and the risks to public health based on real data.
The application fails to address the matter of phosphates, which is a major concern when considering impacts on local watercourses and ponds. It is also unclear how the applicant intends to prevent runoff from the extensive concrete footprint during the cleaning operation. There is an inference that it is acceptable to spread the content of the IPU waste water tank [40cu.m] on the land, on a twice weekly basis.
Poultry manure contains higher levels of phosphates than any other livestock manure. The deposits from over a million birds, year in year out, will pose a serious risk to local ponds, watercourses and wildlife habitats.
In addition to phosphates, the manure contains high levels of molecular nitrogen and runoff can cause algae blooms in freshwater, resulting in reduced sunlight and oxygen supply to water plants and causing the death of fish and other wildlife that inhabit the local ponds.
The steep sloping nature of the surrounding landscape will make it almost impossible to prevent large amounts of phosphate reaching nearby watercourses, particularly during periods of heavy rainfall. All the nearby streams ultimately drain into the River Severn.
The vast majority of the existing farmland is pasture and any spread manure/litter will not be ploughed into the soil. The risk of phosphate runoff therefore increases. There will also be an odour impact in addition to that from existing cattle and sheep manure.
The documentation states that water for the IPU stock and for cleaning will be sourced from either mains supply or an existing borehole. The applicant will require an abstraction license for any significant increase in volume from the borehole.
Within the units, estimated water consumption is at least 100 litres per day per 1,000 birds or 100 x 38 x 7.6 x 150 = 4.33 million litres per annum (E.Ag Guidance for preparing an Agricultural Water Audit for an IPU).
In addition, waste water from IPU cleaning will total 88,300 litres per cycle or 671,000 litres per year giving a total annual water usage for IPU of over 5 million litres.
There are obvious concerns about the effects that abstraction on such a large scale would have on the local water table.
Waste water from within the unit will be collected in a 40,000 litre underground tank that will require emptying at least twice per week. The proposal to spread this amount of water onto farmland is totally unrealistic for this site.
The drainage system associated with the units will be prone to blockage by dust and feed debris and there is a risk that water from within the IPU would run off directly onto the sloping farmland.
In addition to nitrate pollution risk from manure storage in field heaps spreading into surface water and ground water (E.Ag Intensive Farming Guidance) and ultimately local watercourses, any runoff of nutrient rich water from within the units or from cleaning will add to the pollution risk.
100 metres downhill from the proposed IPU at Frochas Farm is Cefn y Spin brook. Other smaller local streams converge with the brook then pass through Lower Llanerchydol Farm and central Welshpool before ultimately draining into the Severn. Big Pond at Lower Llanerchydol is a large imposing stretch of water that enhances the surrounding landscape. All these natural water sources and the habitats they support are at risk from polluted runoff originating from the IPU.
The applicant’s documentation acknowledges that large areas of concrete could cause flooding further down this sloping site and that the cleaning operation could result in dirty water runoff.
The risks attached to polluted water runoff and flooding further down the sloping site, particularly during periods of heavy rainfall, raises concerns about the habitats of local wildlife including swans, herons and moorhens that frequent the local ponds.
The baseline assessment for odour is incorrect, disregarding existing manure smells from the farmland.
Foul odour issues intensify when the units are opened for stock clearance in weeks 5 and 6 of the crop cycle and during the removal of manure and contaminated bedding from the IPU.
Decomposing manure in field heaps are a further source of foul odours that will affect families living in the surrounding areas. The regulations allowing only temporary storage of manure in field heaps appears to have been overlooked.
Dead Animal Storage
The average stock mortality rate within broiler IPUs is independently estimated at 3.5%, in this case 5,250 dead chickens per crop cycle.
The documentation refers to refrigerated storage of dead stock but gives no indication of storage capacity.
The concerns with animal carcass storage are related to odours, vermin and insects (flies) in the local area and adverse impacts on public health.
The application fails to acknowledge the possibility of any major failures in IPU control systems or increased mortality as a result of disease within the units and lacks any effective contingency plans to mitigate the associated effects.
The temperature controlled units stocked with poultry and feed will be a source of vermin. Realistic plans to deal with vermin within the units and the spread of vermin at the times of unit clearance are not evident in the documentation.
Stored manure/spent litter heaps have not been addressed as vermin sources.
The application lacks a robust and preventative plan to control all sources of vermin.
The main sources of dust are bird food and litter. Extracted dust is not filtered and is emitted through the large overhead fans to the surrounding atmosphere along with contaminated air.
The dust extract from the units is a harmful, airborne composition of faeces, chicken dander, mites, bacteria and fungal spores. It can also include traces of veterinary medicines, pesticides and hydrogen sulphide, a cocktail of ingredients unfit for human consumption.
80% of dust emitted is reported as being less than 2 microns and can readily be transported on the wind effecting the centre of Welshpool. It appears to be acceptable for the remaining 20% to be deposited on residents who live much closer to the IPU.
The documentation acknowledges that dust will carry as far as both Brony Buckley and Gungrog, both residential areas.There is no measurement of dust impact on locations between the two, including the local hospital.
There is already a background problem with flies in the local area during spring and late summer.
The proposals to store IPU manure in field heaps or spread it on the farms pasture will create further fly problems and increased risk of infections being transmitted to the local human population. Manure will not be ploughed into soil, unless there is an intention to turn the hillside into a ploughed up manure tip.
The plague of flies that descended on nearby Llanfair Caerenion in 2018 was traced to a nearby IPU (Welshpool Town Council).
The health risks associated with an increase in flies will be discussed in a later section.
Existing background noise is largely from agricultural vehicles, resident’s cars and delivery vehicles and is mainly confined to the daytime hours. There is very little evening or night noise pollution that effects the local population.
The applicant acknowledges noise from the IPU effecting nearby homes and their residents. It is understood the sources of this noise are the intermittent stopping and starting of the roof mounted fans throughout the day and night as well as noise from the units generators.
Additionally the documentation acknowledges noise problems during the night and early hours of the morning from HGV movements used to clear stock from the three units.
The intermittent nature of the noise and working lights at different times of the late evening and night will interrupt sleep and lead to sleep depravation for people in the nearby localities.
Pollution Threats to Wildlife
The diverse population of wildlife thriving on the surrounding parkland, ponds and farmland will be threatened by the industrial amounts of pollutants produced by this large, factory scale, proposed development.
The variety of birdlife includes aquatic species such as swans, herons, ducks, geese, dippers, moorhens and coots, all at risk from water pollution causing loss of fish stocks and water plants.
Similarly, if small mammals such as voles and field mice decline due to pollutants, the existing local wild bird population including kites, buzzards, owls, rooks and ravens will be adversely affected.
The large volumes of airborne polluting emissions from the IPU, will present a high risk to the healthy range of insects in the locality as well as the wide range of small birdlife that depend on them for their survival.
The clean, healthy water of Big Pond has lead to colonisation by freshwater species including carp, pike, tench, newts, toads and frogs. In addition the presence of freshwater mussels provide a strong indicator of the the good water purity in the pond. Nitrate and phosphate runoff originating from the adjacent IPU together with airborne nitrogen/ammonia pollution will wreck this habitat and the creatures it supports.
Endangered species are especially vulnerable to any level of environmental pollution, in particular the Pearl Bordered Fritillary, now found in only a few sites in Wales. One of those sites is Frochas Common, less than 1,000m from the proposed IPU.
High levels of airborne nitrogen can be fatal to the wild flower dog violet on which the PBF depends. The hard work of charities and volunteers, over many years, to protect and maintain this vital habitat is totally disregarded by this proposal as are the endangered species therein.
The Campaign for the Protection of Rural Wales has been very active in raising awareness on a government level about the long term effects of IPUs in Wales on the environment. Further information can be found; CPRW Stats, Data & Maps
“IPUs pose a very real threat to the county’s landscapes, ecosystems and to the tourist industry. We will continue to campaign for appropriate support to be offered to farmers to ensure the future of the county’s small farms.”
Quote from CPRW Brecon & Radnor website.