To: planning@causewaycoastandglens.gov.uk
Subject: Objection to Planning Application B/2015/0005/F

Dear Causeway Coast and Glens Borough Council Planning Office,

I am writing to make a formal objection to the planned pig farm near Limavady, Causeway Coast and Glens (planning application B/2015/0005/F).

The proposed development constitutes a major risk to both human and animal wellbeing, as well as a serious threat to the local environment.

The Risks:

Human health

A US report found that 25% of people working in intensive pig units suffer
permanent lung damage due to the fumes from pig effluent. See the report:
http://infohouse.p2ric.org/ref/21/20042.htm.

There is one residential property within 100 metres of the site boundary, one within 150 metres and another nine within 250 metres. See the plan superimposed on a map here: 

GGD Netherlands (Community Health Service, the Dutch equivalent of Public Health England) advises that “no intensive livestock farm should be built within a radius of 250 metres of sensitive locations”. GGD Netherlands is of the opinion that “when there is a distance of 250-1000 meters between an agricultural development area or company and a living area an additional risk assessment by a health expert must be carried out”. Read a translation of this report here: GGD report: http://farmsnotfactories.org/wp-content/uploads/2015/06/GGD-report-translation.pdf.

Additionally, the conditions in which the pigs will be kept could require routine antibiotic use. The result of this will be antibiotic resistant bacteria diseases that can pass to humans. This, the World Health Organisation (WHO) says, is a “serious concern given the alarming emergence in humans of bacteria, which have acquired, through this use, resistance to antimicrobials.” Read the WHO report: http://web.archive.org/web/20040513120635/http://www.who.int/mediacentre/factsheets/fs268/en/index.html.

Antibiotic resistant bacteria such as  E. coli, salmonella, campylobacter and the pig strain of MRSA will be present inside the units and could be spread by flies or as bioaerosols from the units, from workers, from lorries or from any open tanks or stores to neighbouring residents.

Although an anaerobic digester destroys some antibiotic resistant bacteria, research in Canada has shown that it is not hot enough to destroy clostridium difficile, which has been found in British pigs and can pass to humans. A 2010 report by the Agri-Food and Biosciences Institute found that although anaerobic digestion lowers the pathogen loads in digestate, there is incomplete destruction of some bacterial pathogens such as salmonella, listeria, E. coli and campylobacter. See report: http://www.afbini.gov.uk/afbi-ad-year-1-vo3-web.pdf, p9. If slurry is landspread on third party land, the risks to human health from pathogens and MRSA will be much greater.

In addition, Limavady public water storage tanks are sited less than 200 metres from the industrial scale pig units and slurry tanks. A Water NI trunk main feeding this system runs immediately adjacent to and parallel to the West side of the units. The aerial deposition of ammonium particulates, toxic pathogens and pungent odours are major risks for the contamination of the public water supply for Limavady.

Human Rights, QC's Opinion

Planning Authorities, as emanations of the state, have an obligation under the Human Rights Act 1998 to consider the effects of their decisions on the human rights of affected third parties. The grant of permission in circumstances where there is “reasonable and convincing evidence” that the development in question would have a direct effect on the quality of life of concerned third parties has the potential to engage the Article 8 rights of those third parties, and to confer “victim” status on them under the Human Rights Act in respect of anticipated breaches (R (Vetterlein) v Hampshire County Council [2002] Env. LR 8).   

Read the full letter here: 
https://www.scribd.com/doc/274293607/Human-Rights-QC-Letter-Re-Limavady

Animal welfare

In the Environmental Statement (http://epicdocs.planningni.gov.uk/ViewDocument.aspx?uri=2872228&ext=PDF), Preferred Capital Management (on behalf of Mr Simpson), make no mention of pig welfare. There is therefore no guarantee that high animal welfare standards will be met. Additionally, the sheer scale of this farm – with over 20,000 pigs – will make it impossible to monitor the wellbeing of individual animals, extending animals’ suffering and allowing disease to spread rapidly and to farm workers and the local community (see above).

Environmental impact

Intensive pig factories have a negative impact of the environment and the local area, causing noise, pollution and increased traffic. Two slurry stores will be need to contain all of the waste, risking pollution from odour and contamination of watercourses as well as health threats from bio-aerosols and ammonia.

Indeed, the planning application for a smaller pig farm in Foston, Derbyshire, was rejected on the grounds that, based on the information provided, the Environment Agency “cannot be satisfied that the activities can be undertaken without resulting in significant pollution of the environment due to odour which will result in offence to human senses and impair amenity and/or legitimate uses of the environment”. See report: https://whitehall-admin.production.alphagov.co.uk/government/uploads/system/uploads/attachment_data/file/404990/Foston_Pig_Unit___Anaerobic_Digestion_Plant_Refusal_Decision_Document.pdf. 

Rural livelihoods

If given permission, this pig farm will set a dangerous precedent for the future of intensive pig farming in the UK; it will accelerate the race to the bottom for small-scale UK farms which, due to economies of scale, will be unable to compete. Based on government figures, up to 350 of the smallest pig farms could lose all their sales if the pork from farms like this one hits the market. See this report by the Soil Association and World Society for the Protection of Animals: http://www.worldanimalprotection.org.uk/sites/default/files/uk_files/documents/old_macdonald_had_a_farm_report.pdf. 

In the UK we have  lost  fifty percent of the breeding pig herd over the past fifteen years, largely due to unfair competition from lower welfare, intensive farms in other European countries - many of which operate illegally in breach of the EU Pigs Directive. See this report by Compassion in World Farming: http://www.ciwf.org.uk/research/species-pigs/lack-of-compliance-with-the-pigs-directive-continues-urgent-need-for-change/. 

Conclusion:

We need a food system that puts animals, people and the planet first. I strongly urge you to reject the proposed plans.

Yours truly,