Great Westwick Farm

Objection Comments

I urge the EA not to grant a permit.

1. I object to application EPR/TP3837MY/V005 for an environmental permit to convert from rearing 100,000 pullets to 179,166 broilers at Great Westwick Farm Poultry Unit, Marsh Road, Burnham-On-Crouch, CM0 8NE

2. This application is for broiler places in excess of 85,000 and therefore requires a full Environmental Impact Assessment under Schedule 1, para. 17 of the EIA Regulations 2017. The relevant planning authority cannot grant permission without reviewing the EIA, under section 3 of the EIA Regulations 2017. 

3. The application is for both a 79% increase in bird places and a change of use from pullets to broilers. Since broilers typically generate more manure per bird owing to faster growth and feed difference, and since there is a proposed increase from 2.1 to 7.6 batches per year with attendant litter removal and daily use of a macerator, this constitutes a significant intensification which is a material change of use under section 55 of the Town and Country Planning Act 1990.

3. Applications for environmental permits and planning permission for intensive animal installations need to be ‘twin tracked’. I urge the EA not to grant a permit before this application has planning permission. 

4. The application represents a significant intensification with serious consequences to the amenity of local people, public health, the environment, and the animals. Increases in odours, dust, ammonia, pollution, traffic, manure, waste, dirty water, greenhouse gas emissions, and the impacts on people, sensitive and protected habitats, rivers and the climate,  must all be assessed. 

5. Water from this IPU drains into the River Crouch waterbody. The diffuse agricultural pollution entering the river within this waterbody is already described as ‘chronic’ and the effects of intensive poultry farms on river quality are well documented. Additionally, this is located in flood risk zone 3, requiring a Business Flood Plan. ; the Environment Agency would therefore be reckless in encouraging such additional increase.

 6. Recent cases have placed stringent obligations on factory farming developments such as this one. Following Finch v Surrey County Council [2024] UKSC 20, a project specific greenhouse gas assessment calculation is required for EIA; this has not been provided. The assessment should include the emissions from animal feed, slaughter, packaging, transport, and sale. Following R (Squire) v Shropshire Council [2019] EWCA Civ 888 that an environmental statement would be legally deficient if it failed to assess the wider impacts of the storage and spreading of effluent from an intensive poultry rearing facility. The case of NFU v Herefordshire Council [2025] EWHC confirmed that chicken manure is waste, and the LPA does not need to rely on the farming rules for water if they are not working. The case of R (Caffyn) v Shropshire Council [2025] EWHC 1497 (Admin), implies that the planning authority should assess the cumulative impacts of having multiple intensive agricultural developments in one river catchment before granting permission for another.

8. Furthermore, following R (Animal Equality UK) v North East Lincolnshire Borough Council [2025] EWHC 1331 (Admin), animal welfare is a material planning consideration and the public have the right to ask the planning authority to give moral weight to the horrific cruelty experienced by broiler chickens on factory farms due to both their fast-growing genetics and cramped, crowded housing.  

9. Ammonia and nitrogen deposition from the proposed 179,166 broiler unit may exceed critical thresholds at nearby estuarine habitats such as the International and European sites for nature conservation within 5km – Foulness (Mid-Essex Coast Phase 3) Ramsar, Foulness (Mid-Essex Coast Phase 5) Ramsar, Foulness (Mid-Essex Coast Phase 3) Special Protection Area (SPA), Foulness (Mid-Essex Coast Phase 5) SPA, Essex Estuaries Special Area of Conservation, Crouch & Roach Estuaries Site of Special Scientific Interest (SSSI), Goldsands Road Pit SSSI (Geological feature).

10. Para 193(c)of the National Planning Policy Framework (2024) states that local planning authorities should refuse developments that would result in the loss or deterioration of irreplaceable habitats such as saltmarsh, unless there are wholly exceptional reasons, which there are not here.  

11.  The application is therefore contrary to the NPPF.

12. The Environment Agency should refuse this application.

Great Westwick Farm Poultry Unit, Marsh Road, Burnham-On-Crouch, CM0 8NE