Open Letter to the UK Government, National Assembly for Wales, Public Health Wales, DEFRA, NHS, bodies and officials, councils and the media.
Are intensive poultry units (IPUs) the next public health scandal and how long can the government and councils underestimate the threat of ammonia from IPUs as it becomes the next silent killer?
The Explosion of IPUs
As a community that lives in Welshpool, Powys – a county that is now referred to as the poultry capital of Wales – we are in the process of strongly objecting to a planning application for a large scale intensive poultry unit (IPU) at Frochas Farm that would produce over one million chickens per year emitting over 12 tonnes of ammonia, and could have a devastating impact on the local area and community. The site for this 7,200 sq ft industrial size unit will be located less than one mile from Welshpool high street, a thriving town with a community of more than 7,000 people.
While researching IPUs and the numerous detrimental effects it will have on our community, ammonia emissions and the very serious threat they pose to public health has become a primary area of grave concern and this is mainly due to the lack of research, regulation and guidelines implemented so far by the government and local councils to protect the public’s health from ammonia and other emissions IPUs emit.
In recent years there has been a rapid expansion of intensive poultry units across Wales, particularly in Powys, and the long-term effects that IPUs have on public health and local residents has been entirely neglected. Powys has one of the highest densities of IPUs in Europe, and yet the government and Public Health Wales has failed to conduct any medical research or guidelines into the health risks and long-term health effects associated with intensive poultry units and related emissions such as ammonia, despite all the warning signs pointing to a brewing health crisis.
The prolific planning approval of IPUs by councils has been reported in the media and there has been much attention on the explosion of IPUs across Wales and England. IPUs have been considered farming diversification and as such have been given a free pass to be built at an unprecedented rate with government, local councils and Public Health Wales and England all turning a blind eye to the health threat they pose to the population.
The CPRW (Campaign for the Protection of Rural Wales) drew the Welsh National Assembly’s attention to this matter in 2018 with a large scale petition.
The Human Cost
Disturbingly, very little has been discussed or studied about the serious health effects, possibly fatal, that IPUs are having on the public, especially for those residents that live or work near one of these industrial poultry factories. This is especially disconcerting given the increasingly hazardous location of IPUs, with more and more being approved for planning and built next to schools, in villages, near hospital and other vital community facilities, thus resulting in children, the elderly and vulnerable being exposed to the harmful pollutants IPUs emit on a daily basis.
The Bureau of Investigative Journalism and The Guardian recently reported “that it had uncovered evidence on the state of ammonia emissions, the harm they do (3,000 premature deaths a year could be prevented if they were halved, according to a leading researcher) along with the lack of regulation and monitoring, and the ineffectiveness of current efforts to reduce emissions.”
Given the uncontrollable rate of IPUs springing up all over the country, and the high density of them being approved in cluster areas such as Powys, we believe that the figure of 3,000 deaths is conservative and we predict this will rise considerably given the surge in ammonia emissions that will be recorded over the coming years as a result of this wave of intensive farming.
It is well documented that IPUs emit enormous amounts of ammonia, methane, hydrogen sulphide, nitrous oxide and carbon dioxide, in addition to poultry dust, which is also a seriously harmful composition of faeces, chicken debris, mites, bacteria, fungal spores and veterinary medicines. This toxic concoction goes airborne over communities and residents, and is a major cause of hypersensitivity pneumonitis.
According to DEFRA’s Air Quality Guide, “ammonia reacts in the atmosphere to produce secondary particulate matter (PM) pollutants that are transformed into particles by photo-chemical reactions in the atmosphere.”
Ammonia (NH3) is a colourless gas which is both naturally occurring and manufactured. The main source of ammonia pollution is agriculture, where it is released from manure, and chicken manure is especially high in ammonia. 82 per cent of all ammonia emissions in the UK in 2016 were from agricultural sources.
When atmospheric ammonia is emitted from agricultural sources, it can either be deposited directly onto vegetation and landscapes (dry deposition) or transported within the atmosphere and later deposited through rain or snow (wet deposition). At locations very near to the point source of ammonia emissions, the predominant form is dry deposition, while wet deposition is the predominant form in locations further from the source.
As a pollutant which can have significant effects on both human health and the natural environment, the impacts of ammonia on biodiversity can have a direct toxic effect on vegetation or changes in species composition due to nitrogen deposition, which can result in the loss of sensitive and rare species and habitats
A recognised cause of lung, throat, eye and skin irritation and disease, ammonia poses serious medical and health risks, as cited by the World Health Organisation. The Merck Manual of Medical Information states that “the lower part of the lungs are affected” by ammonia inhalation and that “cancer may develop in the lungs”.
Medical studies also show that higher ammonia concentrations in the air are associated with declining lung function in vulnerable adults, children and asthma sufferers living in the vicinity of intensive poultry units, and anhydrous ammonia fumes have resulted in nasopharyngeal and tracheal burns, airway obstruction and respiratory distress, and bronchiolar and alveolar edema.
People suffering from COPD (chronic obstructive pulmonary disease) living near IPUs have been diagnosed with more acute symptoms than those in non-IPU localities. Incidents of pneumonia amongst the vulnerable also increase in the vicinity of IPUs.
A Cumulative Effect
These recognised medical threats must be a serious concern when considering how many IPUs have been built and are operating across Powys and neighbouring counties, and the snowball effect that IPUs are posing to public health.
The massive amounts of ammonia permitted by Natural Resources Wales (NRW) and the Welsh government is in direct opposition to the UK government’s Clean Air Strategy 2019 which states: “We have already adopted ambitious, legally-binding international targets to reduce emissions of five of the most damaging air pollutants (fine particulate matter,ammonia, nitrogen oxides, sulphur dioxide, non-methane volatile organic compounds) by 2020 and 2030. We are now also proposing tough new goals to cut public exposure to particulate matter pollution, as recommended by the World Health Organization.”
However, in the article mentioned earlier and published on June 13, 2019, The Bureau of Investigative Journalism and The Guardian went on to say “dealing with ammonia, as the evidence we have amassed shows clearly, is an urgent problem, but current schemes to help farmers reduce levels have been slammed as “inadequate” by the farmers themselves, making barely a dent in the rising emissions. What’s more,The Guardianhas found there is likely to be a sizeable gap, potentially of five to seven years, before a replacement system is operating.”
This was after taking into account the new Clean Air Strategy 2019. The article goes on to quote Vicki Hird, farming campaign coordinator at the group Sustain: “Air pollution is a hidden killer, for humans and wildlife, and increasing ammonia emissions from intensive farming need to be addressed urgently.”
In May 2018, a petition from CPRW (Campaign for the Protection of Rural Wales) asked for the Welsh Government to improve controls of the expanding intensive poultry industry and expressed a perceived under-resourcing of Natural Resources Wales (NRW) and a failure of Local Planning Authorities (LPAs) to consider cumulative effects of neighbouring intensive poultry units.
So Where Does the Buck Stop?
From our research and experience in the planning applications process to build an intensive poultry unit, we have found a significant breakdown in responsibility and effective guidelines in monitoring and controlling IPUs and related ammonia side-effects.
The planned IPU which has affected our community, and could be built less than 300 metres from the nearest houses, due to its size falls under Schedule 1 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011, putting it in the same category as an oil refinery, nuclear power plant or chemical installation.
A report for air quality, ammonia dispersion and modelling data is provided with IPU planning applications, and this was commissioned by the applicant, which immediately raises questions as to how data is presented in the application, with the obvious aim to get a planning approval and the necessary permits from the NRW.
For IPU planning applications around Powys, these reports are typically submitted by a local company, AS Modelling & Data, which uses only theoretical computer odour and ammonia dispersion models. We have found that this report is severely lacking in a comprehensive assessment of the ammonia emissions from the applicant’s IPU, as it does not take into account the ammonia and pollution caused from the manure spreading (which is extremely high in ammonia) that goes hand-in-hand with an IPU, due to the massive volumes of poultry waste these factories produce.
The report in no way addresses the effects that the ammonia or other high levels of pollution will have on human health. The data is also only calculated on the dispersion levels in the surrounding area, therefore in no way taking into account the cumulative effect by the number of other IPUs in the area or other ammonia emissions. As ammonia goes airborne and travels, meteorological data is required to accurately show ammonia dispersion. To further demonstrate the lack of seriousness in which ammonia is treated in reports like this, in our case, AS Modeling & Data apparently did not have the required meteorological data so they simply used another meteorological data point 23 miles away, therefore potentially skewing results and data dramatically.
We have also discovered that these reports and modelling data submitted to the council with the planning application are in no way analysed or verified by any other unbiased third party, including Natural Resources Wales, Public Health Wales or the Welsh Government. Staggeringly, planning officers are treating these reports as fact when considering IPU applications, despite the data being theoretical and not providing any studies or scientific research into the damage and impact that IPUs and their ammonia emissions are having on human health.
The Cabinet Secretary for Energy, Planning and Rural Affairs, Lesley Griffiths, announced on June 11, 2018, that she had ordered that guidance be issued to LPAs. The ‘Dear Chief Planning Officer Letter’ was published and advises LPAs “to exercise particular care when considering developments which would bring livestock units within close proximity to sensitive land uses such as homes, schools, hospitals, office development or sensitive environmental areas”. It also emphasises the need to take into account cumulative effects and invites LPAs to participate in future Welsh Government work on nitrate pollution and odorous emissions.
The notable phrase in the statement above is “cumulative impacts” and this should be highlighted. Due to the prolific amount of IPUs that have been swiftly approved by Powys County Council in recent years the result has been hundreds of IPUs being built rapidly across the county that house millions of chickens and now emit tens of thousands of tonnes of ammonia and other airborne pollutants, putting hundreds of thousands of people in the UK at high risk.
A report by the National Assembly for Wales, published in October 2018 titledThe Poultry Sector Reportmentioned that planning applications for poultry units must be determined in accordance with the Local Development Plan and LPAs must take into account the views of statutory consultees (e.g. NRW) and other bodies (e.g. Public Health Wales and local wildlife trusts) as well as anyone else who has a view, including members of the public.
In a letter sent on June 12, 2018, to all Heads of Planning by Neil Hemington, Chief Planner, he called for better assessment and for Welsh planners “to look at how analysis of nitrate pollution and odorous emissions such as ammonia, and their cumulative impacts, can be better assessed in light of local circumstances.”
There is clearly a fundamental issue with NRW’s role in planning applications and as a statutory consultee for intensive poultry units; they are the only organisation that is responsible for providing permits and permissible limits of pollutants, but astonishingly they do not have any data on the damage that these pollutants are having on human health. Their guidelines for IPU applications have no references to the potential impact on human health from ammonia dispersion and by their own admission the NRW pays no attention to human health implications.
To highlight this point, Martin Cox, head of operations, Mid Wales, NRW, wrote the following in an email to Russell George, Assembly Member of Montgomeryshire: “Our statutory adviser role in the planning processdoes not encompass health impacts of air pollutionand the planning authority should seek advice from Public Health Wales if they have concerns.”
We confirmed this by recently asking the NRW how and if they assess ammonia levels and the harmful effects they have on humans when giving out permits for IPUs to operate and go on to seek planning permissions. They responded that they do not assess this as they are not responsible and reiterated to us that Public Health Wales should be consulted in this matter.
However, we have found that Public Health Wales are not formally included in this part of the planning application process for IPUs and are not asked by LPAs to give guidance or regulation on an IPU application. Nor are they given the opportunity to asses the ammonia levels already caused by the density of IPUs in the applicant’s area, and the cumulative effects around communities and the public. This is despite the NRW setting the limits for ammonia dispersion and selectively choosing which DEFRA guidelines to follow, or not.
Public Health Wales have stated that there is a need for a cumulative impact assessment, but have still not set any guidelines, conducted any significant research or provided any recommendations on ammonia or IPUs emissions of ammonia.
We Are All At Risk
As a consequence, we are now at a critical mass point of IPUs and increasing levels of ammonia emissions, and the NRW are solely responsible for providing guidelines that lay out permissible amounts of ammonia from IPUs, but they have no understanding of how continuous chronic exposure to irritant gases such as ammonia is impacting human health.
Public Health Wales, which should have this information have still not been assigned a consultee role in the planning application process, nor are they involved on any level in curbing, limiting or even monitoring ammonia emissions from IPUs.
Clearly there are concerns at the governmental level, but regulations are not being put in place and councils such as Powys County Council are continuing to approve IPUs at an alarming rate, which only serves to exacerbate a crisis in the making, which is being fuelled by the NRW’s and PHW’s incompetence at being able to act on, analyse or monitor the harm ammonia is proven to be having on human health.
The increase in ammonia emissions negatively influences environmental and public health, and is also a major contributor to climate change. For all these reasons, it is vital to have a clear understanding of the sources, deposition and atmospheric behaviour of ammonia and what level of health risks IPUs are posing to the public.
It is wholly neglectful for the government and councils to merely rely on theoretical and statistical models to drive national and regional policy without fully understanding the impact on human health. The UK government and local councils have knowingly underestimated this situation and shown no willingness, understanding or appreciation for the effects of cumulative damage that IPUs have had on human health.
While councils are passing the buck to the NRW, the NRW is sidestepping the issue by passing it onto Public Health Wales, who admit there is a concern and issue regarding ammonia and it needs addressing. But that is as far as it goes.
Meanwhile planning applications for more and more IPUs are sailing through to approval and farmers are investing even more of their already spiralling debt into this type of intensive farming which at some stage will have to be heavily regulated and possibly dialled back, leaving them in a polluted environment with high levels of air pollution, multiple health issues and derelict IPUs littering the countryside.
There is no positive ending in sight for the public or the farmers that will all be hugely affected by this tsunami of IPUs that the government has allowed to get completely out of control.
Critically, why is an organisation, NRW, that has been tasked and assigned to provide guidelines on permissible amounts of air pollution doing so without knowledge on how it impacts human health, when the effects of ammonia on human health have been extremely well documented and scientifically proven?
Ammonia Is An Invisible Killer
As residents living in Wales, we need to know why no research has been carried out on the effects of intensive poultry units on human health, why this has not been factored into NRW’s ammonia emission guidelines, why IPUs are continuing to be approved at an alarming rate when there is no understanding, data or guidelines related to human health impacts, and why Public Health Wales have taken no action to regulate ammonia and why they are not part of the planning process and consulted when clearly the public’s health is so obviously at significant risk.
We demand an independent study is undertaken to gain a comprehensive medical understanding on continuous chronic exposure to harmful gasses like ammonia and its cumulative effects on human health, and what health impact IPUs have on local populations and “sensitive environmental areas”.
Until this is done we believe that an immediate moratorium should be placed on all IPU applications across Wales until there is definitive medical data on the impact of IPUs on human health.
Apart from the worrying air pollution issues raised in detail above, intensive poultry units are also a cause of antimicrobial resistance (AMR), salmonella, campylobacter and the risk of avian (bird) flu outbreaks.
We expect that this matter is looked into and addressed as a priority because the government is gambling with peoples’ health and lives, and this has the potential to become the next asbestos, smoking or blood contamination scandal, with potential legal ramifications.
Residents of Llanerchydol
This letter has been written by a community group living in Welshpool, Powys, Wales, and has been sent to government bodies and officials, councils and the media, such as, but not limited to:
- HRH Prince of Wales
- Welsh Assembly Members
- Powys County Council
- Herefordshire Council
- Shropshire Council
- Public Health Wales
- Public Health England
- Natural Resources Wales
- Minister of Health
- Minister of Agriculture
- BBC News
- The Guardian
- The Bureau of Investigative Journalism
- Sky News
- ITV News
- Daily Mail
- The Times
- The Independant
- Shropshire Star
- The County Times Powys
- Soil Association
- Compassion in World Farming
- Asthma Society
- World Health Organisation