Tips for writing a planning objection

[Date]

Subject: Re Planning Application for Roden Poultry Unit TWC/2024/0933

Dear Sir/Madam,

I am writing to you to provide information about potential significant environmental, legal, and socio-economic issues pertaining to the above application.

The proposed development is one to expand an existing intensive poultry unit, and establish a significantly larger facility, with the new development capable of producing 2.4 million chickens per year, and 320,000 birds at any one time (up from 200,000 birds at any one time). However, the application does not appear to have provided the legally-required information on likely climate impacts - nor does the application include an full assessment of the direct and indirect impacts of the waste produced, which could be significant and have an impact on the environment and public health which are material planning considerations.

Our concerns specifically are:

1. The application may not be compliant with Environmental Impact Assessment (EIA) Regulations regarding climate change

The application does not include a comprehensive assessment of direct and indirect greenhouse gas (GHG) emissions. This is contrary to the Town and Country Planning (Environmental Impact Assessment (EIA)) Regulations 2017. Recent legal precedent from the Supreme Court decision in R (Finch) v Surrey County Council [2024] UKSC 30 ("Finch"), clarifies that GHG emissions must be assessed, and must include both direct and indirect emissions. Legal advice regarding a similar planning application in Norfolk confirmed that a compliant EIA for an intensive livestock unit should include such an assessment.

Intensive livestock facilities produce significant levels of harmful emissions, including methane, nitrous oxide, and ammonia from the poultry itself, as well as emissions from the production and transport of feed, and the handling and disposal of waste. Such emissions significantly contribute to climate change and may not be compliant with national and local climate commitments.

2. The application does not appear to contain an assessment of, or mitigation actions for, the impact of waste

The developer proposes to rely on a manure disposal contract which will take the manure waste to a biomass burning facility. However, it does not set out:

• The location of the biomass power stations intended to handle the waste, in order that capacity can be verified
• The emissions and increased traffic resulting from waste transport to the biomass burner
• The emissions resulting from burning manure (e.g., ammonia and nitrous oxide emissions) - these are potentially significant indirect emissions and thus should be included in an EIA
• How the resulting waste (eg ash from biomass burners) will be disposed of / spread, and how pollution of rivers and sensitive areas will be prevented in the disposal / spreading of this waste.

Without this information, it is unlikely that the full lifecycle GHG and waste impacts have been fully considered.

3. The proposal may contradict national and local policy

The National Planning Policy Framework (NPPF) requires planning decisions to:

• "Support the transition to net zero by 2050 and take full account of all climate impacts."
• "Encourage the reuse of existing resources and minimise waste and pollution."

It is not clear how this application relates to these requirements and may contradict them. In particular, the NPPF now explicitly requires that planning policy and decisions must take a “full account of all climate impacts” (para 161).

Locally, Telford & Wrekin’s climate change Action Plan includes a collective vision for the Borough to become ‘carbon neutral’ by 2030 which means locally: less pollution, cleaner industrial and agricultural processes, better insulated homes, shops & offices.

It includes actions to:

[33] Promote low carbon farming practices and setting aside land for habitat creation

[35] Promote growing beans/peas as low emission crops which improve soil health.

The action plan does not include plans to increase livestock production.

National Climate Policy:

The UK’s target to become carbon neutral by 2050 is written into law. In November 2024, the Prime Minister confirmed the UK Government’s commitment to reducing greenhouse gas emissions by 81% by 2050.

Chicken is a high-GHG food source, while plant-based proteins emit significantly fewer GHGs per kg and per calorie. The UK’s latest Carbon Budget calls for a 20-50% reduction in all meat consumption to meet climate goals, with the National Food Strategy recommending a 30% cut in meat production and consumption. Approval of an increase in meat production is incompatible with these targets.

4. Economic impacts

The proposal is unlikely to represent sustainable business growth. The applicant justifies the proposal on the basis of increasing local food production, but the expansion of intensive livestock farming and increasing industrialisation of the sector has a number of known negative impacts, including:

• Dependence on imported feed: Intensive poultry farming relies heavily on imported feed (e.g., soy), contributing to deforestation and associated global GHG emissions. Livestock is also a major consumer of food grown in the UK – around half the UK’s cereal and grain crops are fed to livestock instead of humans
• Minimal local economic benefits: The proposal is estimated to create just one new job. Employment in intensive livestock units is typically low-paid and insecure. Industrial-scale facilities can undermine and outcompete local, small-scale and sustainable farming. Overall the expansion of intensive livestock farming and the industrialisation of the sector is estimated to have reduced jobs in farming by 14,000.

5. Lack of sustainable alternatives in the application

The applicant has not explored or proposed sustainable alternatives. Agroecological and nature-friendly farming models, such as mixed farming or plant-based protein production, offer a viable and preferable alternative to intensive poultry farming. These models:

• Reduce GHG emissions
• Support biodiversity
• Provide healthier and more sustainable food
• Offer higher economic returns to local communities and more jobs

Such sustainable enterprises can operate even in a relatively small land area. Comparable-sized farms across the UK have successfully adopted low-carbon, nature-friendly systems, demonstrating the feasibility of alternative approaches.

We recommend that the council instead explore opportunities to promote sustainable, low-carbon farming initiatives that align with local and national policy objectives.

Yours sincerely,