Open letter from Prof. Paul Behrens: New planning rules risk food security

OPEN LETTER

Dear Secretary of State for Housing, Communities and Local Government the Rt Hon Steve Reed OBE MP, 

I am writing to you as a university professor in food systems with over 20 years of experience in environmental science. I welcome the Government’s recognition that planning policy is important for our food system, and measures for horticulture, farm shops and on-farm diversification. However, I am very concerned that the proposed revisions to the National Planning Policy Framework (NPPF), particularly the board presumption in favour of agricultural development under policy S5 risk making it easier to approve intensive livestock units in the name of “food production”, undermining the food security, jobs and growth the Government seeks to promote.
 
Intensive livestock farming risks undermining UK food security. Intensive livestock farming is highly dependent on international feed imports. Currently, just under half of UK animal feed is imported. Further, a large share of the micronutrients added to that feed, such as vitamin B6, is also imported, with the UK sourcing the vast majority of its vitamin B6 from China. As Professor Tim Lang set out as part of the UK National Preparedness Commission, it is dangerous to assume that import-dependent production systems will feed us reliably in the future.

Food security is not simply about producing more calories or more commodities in the short term, it is about the long-term ability of a country to have access to healthy food, through diverse systems that can withstand climate shocks, market volatility and geopolitical disruption.
 
We already produce more meat and dairy in the UK than is required for a healthy diet.  Overconsumption of red and processed meat is a major driver of diet-related disease. In the UK alone, obesity and overweight were responsible for nearly 40,000 deaths in 2021, and food-related chronic disease costs the NHS an estimated £67.5 billion a year. Research estimates that even modest meat reduction - such as meat-free lunches on weekdays - could save the NHS £2.2 billion annually. A food-secure Britain is one that can reliably produce healthy food, not one that oversupplies products we should be reducing in our diets while remaining heavily dependent on imports of fruit, vegetables, pulses and feed. According to the UK Food Security Report 2024, the UK produces only 16% and 53% of its fruit and vegetable supply respectively, with vegetable self-sufficiency having fallen from 63% in 2003 and 57% in 2021, and imports are especially dependent on climate-vulnerable countries for these foods. This presents a severe risk in nutritional security and highlights the desperate need to prioritise horticulture over further livestock expansion.
 
Intensive livestock systems actively undermine the natural foundations of food production. They generate large volumes of pollution, often in already stressed catchments. Agriculture is now the leading factor preventing England’s rivers and lakes from reaching good ecological status. This is undermining production: short-term output is bought at the expense of soil health, clean water and climate stability, which are essential for producing food in the decades ahead. 
 
I am also concerned that the proposed planning changes would damage economic resilience. Intensive livestock production is associated with job losses at farm level through consolidation and automation. The UK has lost an estimated 14,000 farming jobs as intensive systems have displaced smaller and mixed farms. Official Defra data confirms this broader trend: the agricultural workforce is now at its lowest level since records began, declining by a further 1.9% in 2025 alone. In contrast, smaller-scale, agroecological and mixed farming systems typically support more jobs per hectare, stronger local supply chains, and more diverse rural economies. From a food security perspective, diversity brings strength. 
 
Planning reform is needed to support the diversification of farming, but it must be the right reform. I welcome the NPPF's support for horticulture, farm shops and on-farm infrastructure as these are precisely the kinds of development that strengthen food security. But as currently drafted, Policy S5 risks creating a blanket presumption in favour of "food production" without distinguishing between systems that support long-term food security and those that make us more vulnerable.
 
We would urge you to consider four changes in particular. 
 
1.    Explicitly support infrastructure like small-scale storage, retail and horticulture, local processors, distribution hubs, farm shops, and local producer markets. This would remove some of the barriers to growth for these enterprises, and protect the UK’s ability to feed itself over the long term while boosting economic growth;  

2.    Prioritise long-term food security (rather than simply production) to safeguard our food resilience in the context of growing geopolitical instability and climate collapse; 

3.    Give local councils the powers and clarity they need to refuse harmful developments and consider cumulative pollution, climate and nature impacts, ensuring planning decisions truly protect rural communities and the environment and; 

4.    Ensure the revised NPPF aligns with the UK’s climate and environmental legislation, including the Environment Act 2021, relevant case law, and the Planning and Infrastructure Act 2025, which commits to ensuring that development delivers measurable gains for nature.
 
The choices we make now about planning and farming will shape the resilience of our food system and our health for decades. Expanding factory farming would be deleterious to food security, healthier diets, and a thriving rural economy. I would welcome the opportunity to discuss how planning policy could instead support a food system that is productive, resilient and fit for the future. 
 
Yours sincerely, 
Professor Paul Behrens

British Academy Global Professor
University of Oxford

Anyone can respond to the government's new planning proposals. The deadline for the consultation is 10th March 2026. Sustain has produced a briefing setting out key risks.

Do you live in a factory farming hotspot? Please write to your MP now using our pre-written letter.