Manor Farm

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1. To: planning.southern@shropshire.gov.uk

   Subject: Objection 25/01501/EIA 160,000 birds Manor Farm Sheriffhales

   To the Shropshire Planning Committee:

   
   

   I object to application: 25/01501/EIA, to house 160,000 birds and the erection of a poultry farm including 4 no linked poultry houses with linked amenity building and associated concrete apron, feed bins, feed blending room, dead bird shed, dirty water tanks, biomass boiler house, hardstanding yard area and drainage attenuation pond and associated landscaping at land southwest of Manor Farm, Sheriffhales, Shropshire, TF11 8QY. I call on the council to commission an independent review of the environmental statement and air quality and odour assessments. The application does not meet the environmental, social, and economic objectives of the National Planning Policy Framework (NPPF) for the following reasons: 

   Social Objective: Amenity 

   1. The awful odours, ammonia and dust pollution which lead to people feeling sick. 

   2. Increased HGV traffic worsens air quality and road damage. 

   Environmental Objective

   1. No assessment of upstream and downstream greenhouse gases from this farm & contribution to climate change (required following the supreme court's ruling in Finch v Surrey County Council [2024] UKSC 20).

   2. In R(Squire) v Shropshire Council [2019] EWCA Civ 888, the EIA was defective because it omitted an assessment of the effects of dust from the storage and spreading of manure [79]. NFU v Herefordshire Council [2025] EWHC 536 further confirmed that the local planning authorities are not obliged to assume regulations like the Farming rules for water will protect the environment. The applicant has not provided an assessment of the impacts of waste (digestate) spreading on third party land or evidence that it will not pollute rivers, or negatively impact amenity or protected sites.

   3. Digesters have been linked to substantial river pollution because after the digestate has been spread on fields, it can wash downhill and into rivers.[2] As Welsh Rivers Trust charity Afonydd Cymru has noted, ADs are having negative effects on efforts to attain of biodiversity improvements.[3] They are complex, industrial plants, many of which are damaging river environments in both direct and indirect ways. They are also a contributor to excessive nutrients in rivers when their end product (digestate) is spread on unsuitable land that is already high in phosphorus and nitrogen. The current state of regulation of ADs is very weak. Afonydd Cymru advises that Planning authorities should include the spreading of digestate from AD plants in their environmental considerations when deciding on new developments such as poultry units. Case studies have demonstrated a link between extremely high phosphorus levels and spreading of digestate.[4]

   4. ADs have also been associated with catastrophic fish kills. Even a human error as simple as forgetting to check the forecast can lead to deadly consequences. In North Devon, an employee negligently spread digestate on a field when it was forecast rain, and the digestate washed into the river, leading the death of approximately 15,600 fish in the River Mole.[5]  Additionally, in 2016, around 44,000 gallons of pollutant leaked into the Teifi from an anaerobic digestion plant near Tregaron. It killed an estimated 18,000 fish on a five-mile stretch of this SAC-designated river, which is renowned for its sea trout (sewin) and salmon.

   5. The Court of Appeal has ruled that all 10 River Basin Management plans in England are unlawful, upholding the Government’s 2027 deadline to clean up all rivers under the Water Framework Directive (SoS Environment v Pickering Fishery [2025] EWCA Civ 378). It would be inadvisable to approve another IPU before the catchment’s river basin management plans are updated. 

   6. Dr Alison Caffyn (senior land use scientist) has written extensively on the problems caused by unsustainable industrial farming in Shropshire, and is currently taking Shropshire Council to court (with River Action) over another IPU near Shrewsbury; the council should await the decision of that case before making any planning decision. 

   7. According to the Catchment Data: The site is in the Worfe River Operational Catchment, which does not achieve good status primarily due to agricultural and land management issues. The closest waterbodies Burlington Bk, Wesley Bk, and Meese, are all in bad or poor ecological condition, due to reasons including: poor livestock management, poor nutrient management, and groundwater abstraction. Two of three are also classed as poor for phosphate.The site is within a groundwater drinking water protected area that is classed as ‘probably at risk,’ and within a nitrate vulnerable zone (surface water and groundwater). Considering the overall poor state of the water environment, it would be irresponsible to approve another IPU. 

   8. No assessment calculations of deforestation linked to chicken feed production.

   9. No assessment of how much water will be used. The country is already facing a drought and water availability crisis, and factory farms use a lot of water. 

   10. Water abstraction is also a cause of declining SAC, SPA, and Ramsar sites and the applicant has not provided information on how much water they are using. Harris v Environment Agency  [2022] EWHC 2264, confirmed that the Habitats Directive requires public bodies to take appropriate steps to avoid the deterioration of natural habitats in special areas of conservation, with regards to water over abstraction. Johnson J stated that ‘abstraction from one location may affect an ecosystem several kilometres away.’  and confirmed the obligation on public bodies to prevent deterioration of European protected habitats sites from the negative impacts of water abstraction.  

   Social Objective: Public Health 

   1. Bird flu risk is high. Millions of birds culled this year already due to bird flu. Scientists say the risk of the next pandemic from bird flu is rising. There is another intensive poultry unit under a mile away, which is less than the 3km biosecurity protection zone required whenever there is highly pathogenic avian flu (the most common type of bird flu).

   2. Antibiotic use on factory farms fuels antibiotic resistance, a growing public health crisis causing over 2000 deaths a year in the UK (UK Health Security Agency). 

   3. Consumption of chicken above 300g/week is also associated with an increased risk of all-cause mortality from gastrointestinal cancers. [6]

   Social Objective: Animal Welfare

   1. Application cannot meet animal welfare needs under the Animal Welfare Act 2006. The Animal Welfare Act (2006) recognised in law that animals can feel pain and suffering and the Animal Sentience Act (2022) recognizes that animals are sentient beings, with emotional and cognitive capabilities. Section 9 of the Animal Welfare Act places a duty of care on people to ensure they take reasonable steps in all the circumstances to meet the welfare needs of their animals to the extent required by good practice, including chicken’s need to be able to exhibit normal behaviour patterns (s9(2)(c)) and the chicken’s need to be protected from pain, suffering, injury and disease. (s9(2)(e)). UK Broiler Welfare guidance also includes the five freedoms.

   2. Factory farms do not allow birds the freedom to express normal behaviour by providing sufficient space; nor freedom from fear and distress by ensuring conditions and treatment to avoid mental suffering. Chickens on factory farms are subject to overcrowding and stress, and broiler breeders are also subject to painful mutilations, which leads to immense suffering. Undercover investigations show that animal abuse, sickness, and extreme suffering is commonplace on factory farms, even on high welfare farms (including RSPCA Assured and Red Tractor).[7]

   Economic Objective

   1. Does not meet the economic objective of the NPPF: Farming jobs have been absolutely devastated by intensification, something often ignored by those putting farms out of business. A study found that between 1961 and 2019, UK meat production increased by 87% yet over the same time agricultural employment reduced by 68%.[1]

   2. The water pollution from excess fertiliser from factory farms is holding up housebuilding just as much, if not more, than the sewage crisis!

   3. Shropshire already has 102 mega farms. There are 1300 intensive farms in England, and the UK exports over £100m of poultry; this IPU is not needed for food security. 
      

   Kind regards,