Viva! Objection to Nocton Dairy
Read below what Viva! sent to North Kesteven District Council to
complain about the proposed mega-dairy outside Nocton, Lincolnshire.
April 9 2010 was the
closing date for this round of objections. Thanks
to everyone who sent one in!
Nocton Dairies have now withdrawn from a planning
meeting that was due to be held on April 27. However, we fully
expect them to resubmit altered plans. So, please keep an eye
out, as it may mean we have more time for further objections!
Check out Viva!'s
Anti Nocton Dairy Facebook group for the most up-to-date news!
Below is the letter we sent to North Kesteven District Council
with regards to the amendments to the plans. Thank you to Linda
Wardale from Vegan
Lincs, who helped provide most of this information! Below it is
our original objection.
For brevity here are the main points from the new
objection to the amendments:
1)
Slurry will be spread for 18 months before an anaerobic
digester is used, which will cause smell and misery for local
residents.
2)
New planning for pipes needs a separate planning application,
but is included in the amendments.
3)
Inevitable ammonia emissions will probably kill off local
grasslands.
4)
The amendments ignore the fact that 8,100 cattle (and their
slurry) will bring flies to the area.
5)
Air quality will still be impacted.
6)
There are significant Neolithic archaeological finds under
the site. Until these have been explored the development should not
even be considered.
7)
Local trees are at risk.
8)
There has been insufficient attention paid to protecting the
water environment.
9)
The volume of traffic to and from the site has been grossly
underestimated.
10)
Animal welfare is not considered when making a planning
decision, but please do point out that this is a welfare disaster
and is the first of its kind in not just Britain, but in all of
Western Europe. It is morally wrong and large units of this kind
increase the risk of disease by the sheer numbers of animals. They
will ignore this, but it is a point that needs making!
"Mr N Feltham
Planning Officer
Planning Services
North Kesteven District Council
Kesteven Street
Sleaford
Lincolnshire NG34 7EF
1
April 2010
Dear Mr Feltham
Planning Application 09/1040 - Nocton Dairy Ltd
I
am writing to you once again from the animal welfare group Viva!.
This letter is further to the comments I have already submitted, and
I wish to make it clear that those comments (on water and other
pollution) are still more than valid and wish them to be considered
fully when you make a decision on planning.
We have many members locally and throughout Lincolnshire, but as I
am sure you are aware this issue - of the proposed intensive dairy
complex outside Nocton village - has gained national, and even
international interest and attention.
We have seen the latest documents submitted by Nocton Dairies Ltd,
and we would like to add further comments and concerns. Again, we
reiterate that we (on behalf of our local and national supporters)
strongly object to the planning application for the proposed 8,100
Cow Dairy Farm on Nocton Fen, and I would like our objections
registered. My reasons are listed below.
It appears that the changes made to the planning application are
minor and does not address the major concerns that we, and many
others, have.
We have been informed that residents have been told by Mr Willes
that the Anaerobic Digestion Unit will not be up and running
for at least 18 months - when the farm has reached its full capacity
of dairy cows. This means that the slurry will be stored AND
distributed (spread) in a conventional manner for a considerable
amount of time, and this raises concerns for:
1. Human Health
2. Environmental Issues
3. Transportation of slurry (affecting local
roads etc.)
4. Damage to Wildlife
5. Air Pollution
6. Water Pollution etc.
Slurry Distribution
The latest map showing the slurry spreading area
and slurry reservoirs/lagoons appear to have had the pipe work
increased by at least 200 per cent. Original plans show existing
water irrigation pipe work and new pipe work joined up and leading
to the slurry storage areas. However on the new plans it appears
that the new pipe work has morphed into existing pipe work. As far
as we can see, most of what is claimed to be existing pipelines
exits into new slurry lagoons. How can they already exist if they
are serving new lagoons? Also, the sheer quantity of slurry - and it
appears to be ('5m' '20m') in millions of gallons - is wholly
unsuitable for so near residential areas. Similar - and even smaller
- slurry lagoons in areas (including those at Mr Willes Devon farms)
appear to have caused considerable smell and discomfort to locals
there. It is almost certain that those in Nocton and Dunston will
suffer a similar unpleasant fate for at least the first 18 months if
the development goes ahead. The plans don't appear to show whether
these are covered or not.
We have been told that the Environment Agencies' Report stipulates
that a separate planning application would need to be submitted for
any pipe work that will be carrying slurry. At the moment it appears
that map has merely been redrawn! The applicant also has a record of
submitting retrospective planning applications. An example of this
is a current Retrospective Planning Application for a Slurry Lagoon
at his farm in Sedborough, Parkham, Devon - Application Number
1/0130/2010/FULM. This particular slurry lagoon has been
constructed, knowingly and excessively larger than previously
approved. This, therefore, raises concerns about the integrity -
and intentions - of the applicant
Objections against the updated Environment
Statement
Noise
·
All readings should be normalised
to 1 metre which they are not.
·
There is no data for animal noise
as this has deemed to be 'insignificant'. However, readings should
have been taken from the herd in Lancashire (as the other readings
were) and extrapolated to 8100 animals. A significant discrepancy
associated with this is the fact that part of the milking strategy
will occur during the night. The noise from milking at 2am it is of
greater impact than 4pm in the afternoon. This is especially
relevant as the sheds are relatively close to residential areas.
·
The Acoustic Survey Methodology
(Appendix 3) states the measurements have been made using the
guidance contained in BS 4142. This is for industrial developments
not agricultural. BS 5502 should be used for agricultural
developments (Farm Buildings, Their Design and Use).
·
The noise meter used to take
readings has been specified, but no details of calibration (dates,
method etc).
·
No detail of modelling from the
trigeneration unit. This will, presumably, use a steam or gas
turbine to provide power and heat, along with air conditioning
units, all of which are noise sources.
Issues excluded from final scope of ES
Vibration
Document states that the nearest dwellings to the
new entrance will be 200m. Houses on Sleaford Road (which is less
than 50m away). The original site plan shows the entrance is only
50m from the B1202 Nocton Road.
Odour
The report admits that no odour modelling has
been done due to there being no agreement between Natural
England/Met Office as to the type of modelling to be used. This is
not an excuse for not carrying out modelling. This point has been
raised by Scott Wilson, who has commented on this report.
Lincolnshire Wildlife Trust have raised issues regarding ammonia
depositions, and these must be taken into account. It is clear that
anything other than a minor increase in deposition will kill
off the local calcareous grassland plants.
Flies
Apparently, impacts from flies have also been
scoped out of the ES as these present no significant impact. Again,
there is no modelling or data to support these assumptions. I would
have thought that a hot summer would produce millions of flies from
a herd of 8100 cows. The same applies to feed storage areas which
are a fly source, as well as from millions of gallons of slurry
(which, as previously stated, will not pass through the anaerobic
digester for at least 18 months).
Air Quality
·
The report states that the baseline
air quality 'would be within the limits of normal agricultural
background levels'.
·
Air quality monitoring should be
modelled if data is not already available, and an impact statement
produced.
·
Table 2 details odour sources and
mitigation management. For slurry, this details using the anaerobic
digestion unit. As this won't be online for possibly 18 months, what
is the plan and method to mitigate odours in the interim? This is
partly covered in the following section regarding the run-off
lagoon. This will be open and if it is a slurry lagoon for untreated
slurry, why will it contain predominantly rainwater?
·
Slurry produced from 1000 cows
equates to approx 83 cubic metres per day!
Archaeology
The report states that there are no cumulative
effects relating to archaeology or cultural heritage. The report
from the archaeological company who have carried out test diggings
state they have found Neolithic finds of some importance from the
area where a slurry lagoon will be built. They state that further
work is required to both analyse the finds and produce further test
diggings. This development must not even be considered until these
further test diggings have taken place.
Flora and Fauna
Report seems to suggest that areas of calcareous
grassland i.e. Verge LWS areas and Dunston Heath Pond are poor
examples and of low quality. Both the Lincolnshire Wildlife Trust
and Scott Wilson do not agree with this assumption, and it appears
to have been made to provide a smokescreen to enable the
development.
On Site Tree protection
We have been told that the North Kesteven
District Council Tree Officer disagrees with the assessment in the
report. As he or she is almost certainly more familiar with the
area, that opinion should take precedence.
Water Environment
Now we want to draw attention to the risk
assessment table. The following summarises the deficiencies in the
plans:
·
No detail of crack control measures
(floors etc)
·
No detail of bunding for reception
pits and other areas. Should detail bunding volumes.
·
How are pits and channels emptied
to facilitate fault rectification?
·
What receptors are there for
flushed slurry?
·
No detail of failure alarm checks
and methodology
·
Pipe test pressure: 1.5x working
pressure. Is this enough?
·
How are flow sensors
tested/calibrated?
·
Testing procedure/methodology for
standby generator
·
Fall-back procedure if the
generator fails
·
Containment details for escaped
mil, hydraulic fluid, fuel etc
·
Details of how many days feed stock
can be held without replenishment.
·
There is no bulk storage on site
for milk as the report state that milk will be loaded direct to
tanker. How will this be mitigated if tankers cannot arrive due to
road conditions (snow etc), industrial action and so on?
·
No detail of silage effluent
storage
·
Anaerobic digester pumps: no detail
of capacity, testing/breakdown procedure etc.
·
It is stated that pipe work will be
installed to industry standard. What standard? It should be stated.
·
Under 'Separated Solids' is states
that separated solids will be placed in 'suitably located field
sources. Aerobic conditions will encourage microbial activity'
Aerobic?? i.e. open to the air. Therefore the separated
solids will be in the open air, with possible leaching to ground
water etc.
·
No methodology for Soil Moisture
Deficit (SMD) testing
·
No mitigation plan for slurry
leakage during NVZ closed season (i.e. no spreading)
·
No digestate spreading plan. This
is required by new DEFRA rules to be <50 Tonnes/hectare
·
No risk assessments for fire etc on
the site i.e. Cow pen areas; Anaerobic Digester; Vehicle fuel
storage; Chemical/Fertiliser storage
·
Estimated slurry storage is stated
as currently 90,000 cubic meters, with an additional requirement of
165,000 cubic metres. New DEFRA rules state a max of 1250 cubic
metres per tank. Allowing for the fact that the existing storage of
90,000 has been there for many years, the additional storage
requires 132 separate tanks.
Traffic Volumes
The report has stipulated that the increase in
traffic volumes will be 'insignificant'. The following should be
born in mind with reference to that statement:
·
Feed:
8100 cows will require 415 tons of food per day. This will require
at least 12 lorries (i.e. approx 35 tons per lorry). This figure is
based on Peter Willes own information from Parkham in Devon where he
milks 1750 cows.
·
Milk:
250,000 litres of milk produced per day. With an average capacity of
10,000 litres this will be 25 lorries. Also, bearing in mind that
the cows will be milked every 8 hours, a proportion of these vehicle
movements will be during the night.
·
This would give a total of 40 lorry
movements per day along with a further 25 vehicles for employees.
The Environmental Statement states 88 vehicles per day. We believe
when the above is taken into account, this is an underestimate.
Animal Welfare
Although we are painfully aware - and believe it
is fundamentally wrong - that animal welfare is not considered when
considering planning applications of this type, we do understand
that a decision must be made with criteria that is currently set.
However, we believe it is only right to state our belief that units
where cows are incarcerated almost all of their lives are not a
natural environment - especially over 8,000 of them. With battery
farming for chickens being phased out - such a proposed project,
which is nothing more than a "Battery Farm" for cows is totally
unacceptable. The size of the farm, which is in essence identical to
American style intensive feedlots, will potentially cause health
concerns for the animals - and even for the people living nearby.
Disease can spread like wildfire
through factory farms - and often necessitates, because of its
unnatural nature, an increase in the over-use of antibiotics.
Keeping animals indoors can also lead to overcrowded, unsanitary
conditions and high humidity which has been shown to lead to high
levels of lameness and mastitis in cows.
We urge you to take note of the issues raised
above and reject the proposed development at Nocton Heath.
Yours faithfully
Justin Kerswell, Campaigns manager, Viva!, BA
Hons, MSc
Viva!
8 York Court
Wilder St
Bristol
BS2 8QH
PS Please ensure that the members of the Planning
Committee for this application have a copy of this letter."
Below is Viva!'s original official objection:
Viva!
8 York Court
Wilder Street
Bristol
BS2 8QH
Planning Department
District Council Offices
Kesteven Street
Sleaford
Lincs
NG34 7EF
28 February 2010
Dear Sir/Madam
Ref: Planning application number 09/1040/FUL Erection of dairy unit at Nocton Heath Lincoln.
I wish to register our organisation’s objection to this application.
We are aware that animal welfare concerns are not usually considered when planning applications are considered, and we have kept this objection to the environmental and other impacts of this proposed unit. However, we would also like to register that we believe that the dairy complex at Nocton Heath will be an animal welfare disaster. The idea that cows will now join the ranks of the factory farmed animals is abhorrent, and it is shameful that British farming is now leading us further towards American style feedlots. No matter what welfare considerations have been put forward in the planning application, this is a wholly unnatural environment that will be detrimental to the health and well being of the 8,100 animals held there. To suggest that this will in the cow’s best interests – as intimated in the planning application itself – is simply ludicrous.
1. Traffic Problems
Access.
The access road to the site is only 50 metres from the B1202 Nocton lane. It also exits onto a 60mph road (B1188). The planning details for this access show that the visibility onto the B1188 is only 4.5 metres. This seems to be woefully inadequate for a slow-moving vehicle (tanker etc) which is joining a road where traffic could be at speeds of up to 60mph. These vehicles would also have to take into account that traffic could be moving into their path from the B1202 only 50 metres away.
Problems would equally apply to large vehicles turning into the site from the North, and having to negotiate traffic travelling North on the B1188.
As the plans state there will be up to 67 vehicles per day visiting the farm - with milk distribution movement being transported throughout the East Midlands, we believe this will cause major traffic problems for Lincoln and the surrounding areas due to this influx of traffic.
Waste Transportation
The submitted plans show no provision for waste to be piped to the waste disposal unit (anaerobic digester) on Nocton fen. Therefore we assume this will be transported from the farm by lorry. The only access to Nocton Fen is either via Nocton village or Dunston village. This would cause an unnecessary increase in traffic to these villages, apart from which large vehicular access in both villages is not good.
2. Environmental Issues
Pollution
The plans show that the farm and proposed anaerobic digester (waste disposal unit) falls into a Groundwater Source Protection Zone (as seen on plans from the Lincolnshire Environment Agency) and it is also an NVZ - Nitrate Vulnerable Zone (as seen on the DEFRA Nitrate Vulnerable Zones map). So instantly there are concerns, given the sheer volume of animal waste that would be produced from 8,000 cows kept in barns!
Waste Water
A study by the National Environmental Health Association in the US (http://www.thefreelibrary.com/Dairy+Feedlot+Contributions+to+Groundwater+Contamination+-+A...-a055884900) found that a building with 100 cows would produce between 100 to 1,000 gallons of waste water a day. It said that: "Concern is growing about contamination from dairy feedlots as an environmental point-source pollutant in groundwater. Large dairy herds concentrate organic waste in a relatively small land area. Wastewater from the dairy milking center, including wastes from the milking parlor and wash pens (urine, manure, feed solids, hoof dirt) and from the milk house (bulk tank rinse water and cleaning detergents) can be a threat both to groundwater and to surface water."
It goes on to say: "Despite significant progress in reducing water pollution, serious water quality problems persist throughout the country. Animal feeding operations (AFOs) can pose a number of risks to water quality and public health, mainly because of the amount of animal manure and wastewater they generate. Manure and wastewater from animal feeding operations have the potential to contribute pollutants such as nutrients (e.g., nitrogen, phosphorus), sediment, pathogens, heavy metals, antibiotics, and ammonia to the environment. Excess nutrients in water can result in or contribute to eutrophication and anoxia (i.e., low levels of dissolved oxygen); in combination with other circumstances, excess nutrients have been associated with outbreaks of microbes such as Pfiesteria piscicida."
Calculation
So, this means that for 100 cows between 100 to 1,000 US gallons is used, that's between 1 and 10 gallons a day a cow.
Multiplied by number of cows (x 8,100) = between 8,100 to 81,000 gallons a day. This translates as (x 365 for the year) between 2,956,500 and 29,565,000 gallons a year.
If we convert that into litres it is (http://www.metric-conversions.org/volume/us-liquid-gallons-to-liters.htm) between 11,191,569.986 and 111,915,699.867 litres. So, that's potentially over 111 million litres of waste water being used each year on the farm - and presumably that doesn't include water for the animals to drink. Although some provision for this has been made, we don't see how this sheer volume of water won't have a negative effect on the surrounding countryside.
Methane
Whilst we understand that the slurry will be processed (and therefore remove the methane via the anaerobic digester), a major concern will be the amount of methane produced by the cows themselves – especially as the barns are to be open sided. The average dairy cow can produce up to 500 litres of methane a day. A recent study from the Journal of Dairy Science states that the savings made from feed changes alone amounts to, on average, 13% (http://www.wattagnet.com/9342.htmlhttp://www.wattagnet.com/9342.html).
Calculation:
500 litres of methane per day per cow X 8,100 = 4,050,000
If we reduce that by 13% we have: 4,050,000 - 526,500 (13%) = 3,523,500 litres daily
Yearly: 365 x 3,523,500 = 1,286,077,500 litres of methane annually (so that’s over 1 billion litres of methane a year form this one new development!). Methane is 21 times more damaging than CO2 to the environment. So we are potentially looking at a CO2 equivalent of over 27 billion litres annually produced by this industrial dairy unit in Nocton.
This means that this development alone will produce as much detrimental global warming contributing gases as a small town. The cows may produce up to 1,286,077,500 litres of methane a year, which (converted) is 1,286,077.5 m3. Density of methane at STP (Standard Temperature Pressure) is 0.68kg/m3, so that gives 874,532.7 kg of methane. 21 times that gives the CO2 equivalent of 18,365,186.7 kg.
Into tonnes that is 18,365 CO2 per year. An average household is about 6 tonnes per year (http://www.communities.gov.uk/documents/planningandbuilding/pdf/319282.pdf) so that’s equivalent to the global warming gases emitted by a town of 3000 houses (3,060 to be exact).
This is only taking into account methane from the cows themselves. This does not take into account the CO2 equivalent from farm machinery, lighting, refrigeration, transport, production of fodder, transport of animals and milk etc. Therefore the final figure will be considerably higher.
Smell and waste
Whilst the application makes provision for “hovering” up slurry three times a day, this will not in itself mean that the unit will not produce smells which might be noticeable to local inhabitants. Slurry on the ground in-between “hovering” – and it will be considerable amounts – will still have the potential to cause odour problems to the local vicinity.
Also
Nocton Dairies Ltd are owned by Parkham Farms - who have farms in Devon and in Lancashire. We have been informed that, in 2008 Parkham Farms were fined £9,000 for polluting a river in Devon and were responsible for killing more than 70 fish. (From a report written by Mike Dunning from the Environment Agency, published 20th November 2008 - the full article can be seen on:http://www.environment-agency.gov.uk/news/99535.aspx?page=3&month=11&year=2008). If this is the case, it does not seem that this company can be trusted, by past experience, not to pollute the local area – regardless of their promises.
The area is home for a rich diversity of wildlife, with barn owls, swans, herons and buzzards being sighted there, also bats use the area as feeding ground and marsh harriers nest in that area. The impact on the local wildlife that this development would create would be detrimental - with hedgerows being destroyed, pollution from construction, noise pollution, possible fuel/chemical and waste spillage. We firmly do not believe that this has been truly taken into account. A development of this size will have a real and tangibly detrimental – and irreversible – effect to the wildlife at the site.
3. Animal Welfare and Disease risk
Units where cows are incarcerated almost all of their lives are not a natural environment – especially over 8,000 of them. With battery farming for chickens being phased out - such a proposed project, which is nothing more than a "Battery Farm" for cows is totally unacceptable. The size of the farm, which is in essence identical to American style intensive feedlots, will potentially cause health concerns for the animals – and even for the people living nearby. Disease can spread like wildfire through factory farms – and often necessitates, because of its unnatural nature, an increase in the over-use of antibiotics. Keeping animals indoors can also lead to overcrowded, unsanitary conditions and high humidity which has been shown to lead to high levels of lameness and mastitis in cows.
We urge you to take note of the issues raised above and reject the proposed development at Nocton Heath.
Yours faithfully
Justin Kerswell, Campaigns manager, Viva!
PS Please ensure that the members of the Planning Committee for this application have a copy of this letter.
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