North Keal Farm
OBJECT NOW!
North Keal Farm
Deadline: 17th July 2026
Please submit your objection to this environmental permit application for an intensive chicken farm in Spilsby, Lincolnshire.
How to Object to the Environmental Permit Application
Copy the objection comments below.
Click the ‘Object Now’ button below.
Scroll down on the Environment Agency page and click ‘Share your views.’
At Question 4, copy-paste the objection below.
Objection comments
I object to application EPR/UP3624MF/A001 for an environmental permit to rear 265,000 broilers on a new greenfield site, in 6 poultry houses with heat provided by LPG. The application is for North Keal Poultry Unit, Main Road, Spilsby, PE23 4BB.
1. The site address is variously listed as PE23 4BB (Main Application) and PE22 9RL (Site Condition Report).
2. Paragraph 3b of the application has been ticked to confirm that the management system covers climate change adaption, but there is no evidence of this in the summary document provided.
3. The permit will lead to significant amounts of slurry, yet questions about slurry in the application are answered as if there were no slurry.
The nontechnical summary states:
“At depletion the litter will be removed from the site and exported to a Power Station” and “Washings from poultry houses and yards directed to underground dirty water tanks and removed for spreading on third party land”.
The nontechnical summary also states “Records of tonnages of litter and wash water exported off site are recorded”.
The technical standards state that “Drainage from animal housing and water from cleaning out will be collected in underground storage tanks as shown on the site drainage plan”. It also states that “The wash water tanks are built to conform to SSAFO Regulations specifications in SGN EPR6.09“.
The regulations referred to in SGN EPR6.09 are the Water Resources (Control of Pollution) (Silage, Slurry and Agricultural Fuel Oil) (England) Regulations. According to those regulations, slurry is defined as follows.
“slurry” means liquid or semi-liquid matter composed of—
(a) excreta produced by livestock while in a yard or building (including that held in wood chip corrals); or
(b) a mixture wholly or mainly consisting of livestock excreta, livestock bedding, rainwater and washings from a building or yard used by livestock,
of a consistency that allows it to be pumped or discharged by gravity at any stage in the handling process;
Furthermore, SGN EPR6.09 states that “Drainage from animal housing and water from cleaning out is considered to be slurry and should be collected in a tank or lagoon prior to land spreading or disposal”.
4. The site condition report states that the site is located within a nitrate vulnerable zone (NVZ). Storage of manure and slurry in such zones is subject to special requirements.
https://www.gov.uk/guidance/storing-organic-manures-in-nitrate-vulnerable-zones
Yet there is no reference to these requirements or management of them in the application or any of the accompanying documents.
5. Effect of contingency arrangements
The technical standards state that "Litter will be sold to a Power Station.
Any litter that is exported from the installation has records kept of the quantities, destination and the date of transfer.
Contingency arrangements are in place with surrounding farms to accept the manure in case of an emergency.
In these circumstances where the litter is exported for spreading to land, records are kept of the names and addresses of the receiving farms”.
The nontechnical summary states “Washings from poultry houses and yards directed to underground dirty water tanks and removed for spreading on third party land”.
The applicant should provide a map of receiving land to ensure waste is not simply being moved within the same NVZ or to another NVZ. Given the state of our nation's water bodies, this is crucial to avoid additional water pollution.
6. Incineration
In the document identified as “waste minimisation” the applicant states “Poultry carcasses are, under normal circumstances, collected and stored in sealed containers awaiting regular incineration in an APHA approved incinerator or collected by a licensed collection agent”.
If incineration is intended, the atmospheric impact of burning fallen stock from a 265,000-bird population must be included within the emissions and odour data.
7. Errors in waste management plan
Paragraph 1 states that the objective of the waste management plan is to ensure compliance with the Agricultural Waste Regulations 2006. There are no such regulations.
Paragraph 5 states “The Agricultural Waste Regulations 2006 permit the storage of Non-Hazardous waste for a period of up to twelve months. Waste stored must be in a secure place, which will prevent material blowing away or causing any form of pollution to the environment”.
As previously stated, there are no such regulations.
The Hazardous Waste (England and Wales) Regulations 2005, section 16 of which included agricultural waste from 15/5/2007, do not contain any exemption for storage for 12 months for non-hazardous wastes:
https://www.legislation.gov.uk/uksi/2005/894/data.pdf
Paragraph 2 states:
“Main types of waste produced will be;
Paper and Cardboard – generated from chick boxes/tray liners, corrugated rolls separating chicks from walkway during placement, some packaging boxes, paper hand towel.
Plastics – this will be in the form of plastic containers (eg. Empty disinfectant containers), packaging (shaving bale wraps), disposable coveralls.
Glass – light bulbs, fluorescent tubes.
Fallen stock”.
Paragraph 3 states:
“Per crop will produce approximately:
Variable amounts of packaging boxes and paper towel.
200 kgs of plastic wrap, 100 disinfectant/detergent containers, 12 coveralls.
Variable, NB – Fluorescent tubes would be returned to Company stores by operator for collection. (hazardous waste)
Expected mortality 3%”.
The Wastes List referred to in the Hazardous Waste (England and Wales) Regulations 2005 includes (inter alia) fluorescent tubes as follows:
20 01 21* fluorescent tubes and other mercury-containing waste
https://www.legislation.gov.uk/eudn/2014/955/data.pdf
Paragraph 3 states that “Fluorescent tubes would be returned to Company stores by operator for collection” and paragraph 7 states “Recycled waste is sent back to the company’s field stores for storage prior to reclamation”.
Part 6 of the Hazardous Waste (England and Wales) Regulations 2005 requires documents to be completed whenever hazardous waste is removed from premises. The recording sheet in paragraph 7 is not sufficient for hazardous waste.
As regards non-hazardous waste, the recording sheet in paragraph 7 also appears to be insufficient to discharge the duty to apply the waste hierarchy as required by Regulation 12 of the Waste (England and Wales) Regulations 2011
https://www.legislation.gov.uk/uksi/2011/988/contents/data.pdf
https://www.gov.uk/government/publications/duty-of-care-waste-transfer-note-template
Paragraph 6 states “The preferred method of disposal is to be sent for recycling, the local Environment Office can give details of licensed premises able to accept a variety of wastes for recycling.”
There is no public body called the Environment Office.
8. Based on the nontechnical summary which states that there will be 7 to 7.5 cycles per year, the proposed total number of chickens confined for meat production is between 1,855,000 and 1,987,500 every year.
A public authority which has any functions exercisable in relation to England must from time to time consider what action the authority can properly take, consistently with the proper exercise of its functions, to further the general biodiversity objective.
https://www.legislation.gov.uk/ukpga/2021/30/section/102
This applies to the Environment Agency, which is a “public body”.
The Environment Agency states that by 2050 it looks “to nature and nature-based solutions to reduce environmental risks and create more naturally functioning places, catchments and landscapes with ecological corridors, and bio-secure climate-smart agricultural practices the norm”.
For 2026/2027 the Environment Agency’s priorities include “continuing to work with farmers on their environmental performance, through farm inspections and by supporting environmentally friendly farming practices”.
Animal farming at current levels is unsustainable without imports - soy from South America makes up 18% of produced animal feed.
Farming occupies around 70% of the UK land surface. Nature-friendly farming remains essential to both nature recovery and broader environmental goals.
Loss of biodiversity is a national security issue.
The EAT-Lancet Commission found that food is the single strongest lever to optimise human health and environmental sustainability on Earth.
https://eatforum.org/wp-content/uploads/2025/09/EAT-Lancet_Commission_Summary_Report.pdf
Agriculture and rural land use are the main sources of nitrogen and phosphorous pollution.
https://researchbriefings.files.parliament.uk/documents/POST-PN-0755/POST-PN-0755.pdf
The impact of spreading digestate/manure/slurry as fertiliser must be taken into account.
https://www.bailii.org/ew/cases/EWHC/Admin/2025/1497.html
Scope 3 emissions should be taken into account.
https://www.bailii.org/uk/cases/UKSC/2024/20.html
Animal welfare considerations may be taken into account.
https://www.bailii.org/ew/cases/EWHC/Admin/2025/1331.html
The world simply doesn’t need more intensive animal agriculture creating pollution of air, soil and water (locally and nationally), greenhouse gas emissions (internationally), pandemic risks (internationally), loss of biodiversity in the places where the animal feed is grown (internationally), antibiotic resistance (internationally) and of course more suffering for the animals reared in such facilities.
I urge the Environment Agency to reject this application.