Climate change, pandemics, global responsibility and future food policy

The IPCC report Climate change and land (Aug 2019) recommends wealthier countries reduce emissions by supporting an overall reduction in meat consumption, accompanied by a focus on the sustainability of remaining meat production, with resulting benefits for climate, environment and human health.

Intensive livestock production is implicated in accelerating rates of deforestation, given its huge demands for land to grow feed crops. In this way the Welsh poultry industry offshores substantial environmental harm to poorer parts of the world is also reliant on heavy fossil fuel use for the production, import and delivery to remote farms of poultry feeds. [See Bureau of Investigative Journalism report (25/11/20): links deforested areas of the Cerrado, Brazil to soy received at Cargill’s poultry feed mills in Hereford.] The calorific value of intensively reared meat is less than that of the feedcrops, making intensive rearing an inefficient means of feeding a growing global population.

The rising human demand for meat protein and consequent intensification of production is recognised in the United Nations report Preventing the Next Pandemic: Zoonotic diseases and how to break the chain of transmission (July 2020) as one of the seven human-mediated factors driving the increasingly rapid emergence of zoonotic disease.

At the same time the health consequences of closely confining animals drives up antibiotic use, raising the risk of antimicrobial resistance. The additional health costs of the typical meat-heavy, processed ‘Western’ diet include rising rates of obesity and chronic disease. The urgent necessity for UK policy makers to support genuinely sustainable food production and enable all citizens to access healthy foods are key messages of the recent National Food Strategy Part One (July 2020).

Welsh intensive poultry and pig livestock rearing units (ILUs) are disproportionately concentrated in Powys

We estimate that 80% of the intensively reared chickens in Wales are in Powys Local Planning Authority Area (3,856km). Although total numbers are less extreme, over 60% of the intensively reared pigs for fattening in Wales are also in Powys LPA area. [See branch report ‘Intensive pigs in Powys’.] Powys hills and valleys form the headwater catchment of the Wye and Severn rivers. The planning area excludes the Brecon Beacons National Park and is just under one fifth of Wales.

Only roughly 1/4 of the chicken units are over the 40,000-bird threshold (mainly the larger broiler units as opposed to free-range egg units) for NRW regulation through the Environmental Permitting system. None of the pig units are regulated, the largest being 1980 pigs (threshold: 2,000). We recognise that unregulated intensive cattle farming is also a problem which affects all Wales but other parts of Wales more severely than Powys.

Impact on rivers: intensive livestock units (ILUs)

ILUs introduce nitrates and phosphates which cause eutrophication and so impoverishment of freshwater ecosystems. Diffuse pollution from agricultural sources can account for over 60% of river phosphates. ILU operation potentially causes contamination with other pollutants/poisons such as pesticides, veterinary medicines, cleaning products, heavy metals etc. Manure comes from intensive rearing sheds and “free-range” egg-layer ranges and is mostly spread on adjacent land although a small proportion goes to anaerobic digesters, yielding digestate that is also spread on land.

Manure/slurry enters watercourses via surface run-off or hydrological pathways from storage or dirty water leaks. Manure Management Plans are provided for planning purposes. These use a spreading allowance of 250kg/Nitrogen/Ha/Yr., approximately 150% of the allowance in a nitrogen vulnerable zone (NVZs). NVZs are absent in Powys and cover less than 3% of Wales compared with 55% of England.

The state of the river Wye in 2020 has prompted questions about the proliferation of intensive livestock farming in Powys and the reliability of NRW river monitoring for phosphate and nitrate concentrations. NRW has initiated a review and recently confirmed that widespread failure of SAC rivers throughout Wales against the phosphate targets is predicted. NRW says it is likely to advise that all phosphate producing development within failing SAC catchments will have to demonstrate neutrality or improvement of phosphate levels. Also, exploratory visits by NRW to Powys poultry units have revealed a “general issue” of Manure Management Plans and other protective measures not being followed.

Impacts on other Habitats/Biodiversity

Ammonia emissions and nitrogen deposition from air-borne ammonia continue to rise due to agricultural sources. [See Plantlife report: We need to talk about nitrogen and Stockholm Resilience Centre ‘Nine planetary boundaries’] These are reducing plant biodiversity throughout Wales and will inevitably lead to further extinctions, not only of plants but of whole ecosystems dependent on plant diversity. Ammonia emissions also contribute to the human health impacts of traffic pollution. Pollution from ILUs is largely regulated at the planning stage by NRW guidance which sets allowed thresholds for internationally designated nature sites, SSSIs and Ancient Woodland. The impacts are modelled using geographical grids derived from only 5 recording sites in Wales (APIS). The allowances for Ancient Woodland, and all national and local nature reserves and sites, permit any new unit to contribute ammonia or deposited nitrogen sufficient to eradicate populations of lower plants, with no reference to the background level which is often already above the risk threshold. Modelling only considers sheds and chicken ranges and not the emissions from manure/slurry which significantly increase the impacts.

Legislation and Regulation

The Welsh Government’s Environment (Wales) Act and the linked Resilient Wales Goal in the Well-Being of Future Generations Act should have acted to prevent the environmental catastrophe which we are facing in Powys but it has not. The SMNR duties required of NRW and the Section 6 duties required of public authorities have not been met. The Chief Planner has written to LPA Planning Heads about achieving a net increase in biodiversity and considering cumulative impacts but this advice has been consistently evaded. Potential harm to biodiversity outside SACs and SSSIs is simply ignored. Cumulative impacts are not considered properly. Mitigation in the form of manure export to anaerobic digesters and minimal tree planting is readily accepted without any evidence or understanding of the impacts.

In October 2020, after a summer of publicity about the destruction of Wye ecosystems from algal blooms and days after the Powys Head of Planning was present for NRW’s statement about failing Special Areas of Conservation, Powys approved an IPU with manure spreading on riparian fields of the Wye SAC, the 13th approval in the past 5 months.

The Welsh Government has been advised about the impacts of the concentration of intensive livestock farming in Powys and has failed to come up with the promised Water Pollution Regulations, promised for January 2020 and similar to regulations already in force across the rest of the UK, or a promised Technical Advice Note addressing the issue. A huge amount of damage has already been done and continues to occur, all needing to be remedied. Wales Environment Link, a network of environmental bodies working across Wales, have called (Sep 2020) for a moratorium on new intensive poultry sheds in Powys until the environmental impacts of those currently operating has been researched.

The Welsh Government champions a “vibrant industry” and “Welsh Brand” of farming produce ignoring the fact that this is a globally irresponsible, unsustainable farming practice whose direct harmful environmental impacts are outsourced to Powys by large international companies with English headquarters.

The First Minister made biodiversity and environmental growth a top priority for his delivery over the remainder of this Assembly term, declaring a climate emergency in April 2019. We also note that the WG Nature Recovery Action Plan published on 15/10/20 has a Governance theme including “Implementation and evaluation of the section 6 duty across the public sector”. Only urgent action now will ensure this aspiration is achieved.

The Powys Nature Recovery Action Plan was to have been published in late 2018. There would appear to have been no progress since the commission of investigative reports in 2016.

(Much of the text above is found in expanded form in CPRW B&R letter (2/11/20) sent to the Committee for Climate Change, Environment and Rural Affairs. Download the full letter, with additional references, here.)

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In determining planning applications, planning officers should assess the ‘planning balance’ i.e. the relative weight of benefits of the development, in the form of income to the farmer and employment opportunities, against negative impacts which may include any or all of the following:

1. Ammonia emissions: point and area source
2. Nutrient pollution (nitrate and phosphate) to soil, ground and surface waters; Run off pollution potentially including veterinary medicines, pesticides, cleaning products, disinfectants,  fuels and oils and other biologically active materials, from ranges, verandas, washing out, tracks and roads etc.
3. Ecology, other than the impacts above
4. Landscape character and visual impacts
5. Potential impact on listed buildings/conservation areas
6. Traffic – regular movements of large vehicles, sometimes on small roads, sometimes necessitating hedgerow removal, widening/straightening of minor roads (safety, noise, amenity, vibration etc.)
7. Noise impacts on neighbouring properties
8. Odour impacts on neighbouring properties
9. Toxic poultry dust impacts on neighbouring properties
10. Ecological implications of emissions from the development, construction, ancillary development, highways modifications etc.
11. Potential impact on archaeology from range management practices, construction, ancillary development, highways modifications etc.
12. Water requirements and impacts on private water supplies

Further considerations:

1. Sustainability of the development
2. Global responsibility
3. Tourism
4. Light pollution
5. Vermin and flies
6. Accuracy of assessment of economic and employment benefits

[Published December 2020]