Open Letter – Powys County Council’s strategic oversight concerning the overall number and continual approval of Intensive Poultry and Factory Farms.
Dear Dr Turner, Cllr Harris and Mr Davies
This letter is sent by and on behalf of a large and ever growing number of extremely concerned Powys residents who live in close proximity to existing or proposed Intensive Poultry Units (IPU).
We are increasingly concerned that Powys County Council appears to be effectively rubber-stamping approval of a flood of these applications through the planning process, without apparent consideration of the overall impact on the County.
There have been 130 completed applications for IPUs in Powys since June 2015 – and virtually all of them (over 96%) have been approved. There are 29 more in the pipeline.
Our concern is that no-one is properly and thoroughly considering the wide cumulative impact on our environment and on the health of all those adults and children – our families and friends – who live in Powys.
THE PLANNING PROCESS
Two of us were present at a Planning Committee meeting earlier this year.
The planning lead was unable to answer a Member’s question about the total number of IPUs that have been approved in Powys. There was discussion on when Powys would reach saturation point for these (in terms of air quality and manure management) or indeed whether it had already passed beyond that point.
The planning lead explained that the role of Planning Committee is to consider the individual application in question and that decisions concerning Powys-wide saturation points would be made at a higher level at some point in time.
It is clear that whilst the cumulative impact is considered, it is limited to consideration of each individual application taking into account only similar nearby factory farm units. Even more concerning, is that even this narrow review is only based on desktop studies and predicted levels without any actual measurements being assessed.
We understand that The Welsh Government has instructed that the environmental and residential impact of IPUs must be looked at cumulatively, so could you please explain what processes you have in place to consider the wider environmental and human health impacts, and how the impacts of the existing factory farms on the environment and human health are actively and regularly measured (e.g. dip-sample air and water quality measurements)? And who has overall accountability for this? The planning lead’s reference to someone ‘at a higher level’ is worryingly vague!
PROTECTION FOR THOSE LIVING NEAR TO IPUs
Health risks associated with living near to an IPU are increasingly being documented. For example, there is evidence that living near poultry farms (i.e. within 1.15kms) is associated with an 11% increased risk of community acquired pneumonia.
A number of protections are written into local and national planning guidance, such as for those living within 400 metres of a proposed site. In any case, the intensity should be appropriate to the location and setting and have no significant detrimental effect on the vitality and viability of adjacent land uses (residential family homes). Additional traffic generation should not be incompatible with capacity of local road network. We are concerned that little regard seems to be paid to these protections for people living very close by currently.
Nuisances as “predicted” by applicants’ desktop studies often turn out to be grossly underestimated. This means that local people suffer noise levels, particulate and gas pollution (ie. ammonia mainly, but also methane, nitrous oxide, and carbon dioxide), smells and flies, all at unacceptable levels. We do not understand why environmental health officers appear to always agree with the applicants’ predictions even though they are often so wrong in reality.
We cannot find a single occasion where Powys has refused permission for an IPU based on the impact on those living close by, nor on the cumulative effects of the emissions, namely ammonia, other gases and particulates. We are therefore forced to question if approval is weighted towards seeking ways to accommodate, without genuine consideration of the many negative impacts on neighbouring residents and the wider community.
LINK BETWEEN FACTORY FARMING AND VIRUSES
There is growing scientific evidence that factory farming significantly increases the risk of virus epidemics many of which can transfer to humans, which we are all only too aware of now. Bird flu is one of these, and with the approval of every extra IPU, that risk increases.
1000m exclusion zones on IPUs were put into place by Public Heath England after the bird flu outbreaks late in 2019, yet Powys still allows these to be built considerably closer to people’s homes, despite the protections offered in existing planning guidance.
Is anyone in Powys keeping count of how many million birds are now accommodated in the IPUs in our County? Could you please explain how Powys considers this growing risk to public health increased by each additional factory farming unit approved?
We are also concerned that insufficient consideration is being given to the impact on our highways. Each additional IPU brings many more HGV and tractor movements, resulting in increased wear and tear on the road surfaces, delays to other road users, air pollution, noise and increased risk of accidents. Additionally, many of these movements will be at unsociable hours, passing close by to residential property.
We understand that Herefordshire CC, concerned about environmental impacts upon the river Wye, currently has a moratorium in place on all planning applications whilst it considers environmental impacts. Shropshire CC it seems, is refusing a greater percentage of IPU applications, than is Powys CC.
THE FUTURE IN POWYS
We are aware that, recognising the many issues arising from factory farming, the Welsh Government has appointed a committee to produce a new intensive factory farming TAN to assist planning officers in their decision-making process when considering such future applications.
We ask that you urgently:
- Implement a moratorium in respect of all current and future IPU and other intensive factory farm applications until you are able to accurately take stock of the current situation.
- Undertake a comprehensive environmental survey to ascertain if current air and water quality in parts of Powys with a concentration of IPUs are near, or already beyond, saturation point.
- Properly assess the human health considerations to residents posed by the already large number of factory farms present in Powys (based on actual studies rather than desk-based predictions).
- Provide details of how Powys CC takes into account the provisions of the’ Well-being of Future Generations (Wales) Act 2015′ when determining applications.
- Cease determination of all IPU applications until the new Intensive farming TAN is in place to properly guide planning officers in their decision-making process.
We would also ask you to respond to our highlighted concerns above. Please could you respond by email to firstname.lastname@example.org
- The Residents of Berriew Group
- Llanerchydol Residents – Welshpool Frochas Group
- Upper Gwestydd Residents Group – Newtown
- Ardleen Residents Group
- Llangadfan Residents Group
- Llanwnog/Pontdolgoch Residents Group
- Campaign for the Protection of Rural Wales (MontgomeryshireBranch)
- New Mills Residents Group
- Sustainable Food – Knighton
- Zero Carbon Llanidloes
Copies to the Powys Members of The Senedd
This open letter will also be copied to other interested parties.