Pear Tree Farm

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Email to: planningadvice@sholland.gov.uk

Subject: Ref: H23-0313-25 Pear Tree Objection 

Dear South Holland Planning Committee:

I object to the Holbeach Poultry Ltd. application H23-0313-25 to build 12 poultry houses and keep 552,120 birds (690,000 permitted) at Pear Tree Hill Road, Whaplode Drove, Spalding PE12 0SL. I request that you publish my response publicly and give you permission to do so. 

The application will not meet the aims of the National Planning Policy Framework. I object on amenity, public health, environmental, economic, food security, and animal welfare grounds, as identified below.

1. Amenity

2. It is well established that intensive livestock causes odours, air pollution, dust, and flies which are unacceptable to residents. This Intensive Poultry Unit (IPU) plans to keep 3.8 million birds, turkey, or ducks a year, which can cause terrible odours.

3. The local roads are in really poor condition, suffer general subsidence and severe cracking, and not built for high levels of HGV movement. The applicant’s assessment on the impact on highways is insufficient: they have not done a California Bearing Ratio test, which should be required, and the 2884 HGV movement a year will inevitably increase the likelihood of significant repairs needed and cost to taxpayers. No impact assessment taken on increased air pollution from 2884 annual HGV movements. 

4. Environment, Wildlife, Climate Change, Rivers & Muck

5. 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, at [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.

6. The applicant has not provided an assessment of the impacts of waste spreading on third party land or evidence that it will not pollute rivers, negatively impact protected sites, or cause a nuisance from odours and dust to residents living near those areas where the manure is spread. Th applicant’s approach is unlawful.

7. Unlawful lack of environmental impact assessment quantifying upstream and downstream greenhouse gas emissions, which is required following the supreme court's ruling in Finch v Surrey County Council [2024] UKSC 20. Emissions from the supply chain for chicken feed (including as a result of deforestation to grow feed), as well as from slaughter, packaging, delivery to markets, and food waste, should all be quantified.

8. Lack of environmental impact assessment of deforestation caused by feed produced for these chickens. Reports by Greenpeace and Milieu Defense conclude that certification does not work to prevent deforestation. The EIA should take into account the risk of human rights breaches due to deforestation on indigenous peoples and local residents of forests in addition to the GHG and biodiversity loss impacts from any imported animal feed.

9. The site is in a priority area for Countryside Stewardship measures addressing Lapwing habitat issues, yet Lapwing birds are not assessed in the ES, and they are vulnerable to the increased risk of bird flu from this installation as well as increased air pollution.

10. The National Biodiversity Atlas shows 122 different species of birds in a 5km radius, and Daubenton’s bat within just a 2km radius. The environmental statement says nothing about how the air pollution will impact bats and birds. Great Crested Newts have also been cited within a 10km radius, and there is no assessment on the impact of increased water usage on protected species of wildlife. 

11. This site is in the Nene Lower operational catchment, where three out of the four waterbodies do not have good ecological status. The site is very close to a Nitrate Vulnerable Zone, which is a statutory recognition of the area's existing risk from agricultural nitrate pollution.

12. Factory farming in South Holland can produce up to 272.24 tonnes of animal waste every day. This creates 3565.21 tonnes of nutrient pollution every year; this IPU will just add to the problem for rivers. Our rivers are already in crisis from the combined onslaught of a failing sewerage system, factory farming, and highway run off.

13. 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. 

14. The site is in a flood zone, there is about a 39.5% chance of flooding over the next 50 years (given a less than 1% chance each year), and the farm plans to be operational for that long. The Environmental Statement does not adequately the consequences of what would happen in the event of flooding to A) the birds themselves, and B) the colossal amount of polluted waste in 12 no. poultry houses running off into the nearby water courses. 

15. Lincolnshire already has 146 mega farms, and the highest number of confined animals in the UK. There are 1300 intensive farms permitted in England, and the UK exports over £100m of poultry; this IPU is unnecessary for food security.

16. Permit would allow stocking density of 690,000, applicant has only reduced due to requirements from client, but the client could easily change to a lower standard. All impact assessments should be recalculated with the 690,000-bird stocking density as the worst-case scenario, including vehicle movements, water use, GHG emissions, and muck. 

17. Public Health, Bird Flu, Antibiotic Resistance

18. The factory and increased traffic will cause air pollution and dust; a serious public health risk, and cause health risks to workers. There are 4,400 people in the Whaplode and Holbeach St John’s Ward, and this puts them at risk of ill health due to increased air pollution (ammonia, particulate matter).

19. This intensive poultry farm will lead to more antibiotic overuse leading to antibiotic resistance which kills one million lives per year. The UK Health Security Agency says deaths are on the rise with over 2000 people in the UK dying a year from antibiotic resistant infections. 

20. There is another factory chicken farm just 1.8km 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). Lincolnshire is a hot spot for bird flu. Scientists say the risk of the next pandemic from bird flu is rising. 

21.  Consumption of chicken above 300g/week is also associated with an increased risk of all-cause mortality from gastrointestinal cancers, as well as increased cholesterol, carcinogens, and exposure to harmful pathogens. This installation increases the risks of chronic disease.

22. Economy

23. The application does not meet the economic objective of the NPPF: Farming jobs have been absolutely devastated by intensification. A study found that between 1961 and 2019, UK meat production increased by 87% yet over the same time agricultural employment reduced by 68%.

24. Factory farming is destroying nature and holding up housebuilding because new houses can’t be built because the water is already so polluted from the over-use of manure from factory farms.

25. No information given on how much water will be used. The EA chief executive says that lack of water is an ‘existential’ threat. The nation is already suffering from lack of freshwater with droughts increasingly common. This will negatively impact arable agriculture and businesses. 

26. Animals

27. Animal Welfare is a material planning consideration, as confirmed in Animal Equality UK v North East Lincolnshire Borough Council [2025] EWHC 1331 (Admin) at [20]. The application should be rejected as it will not meet the welfare needs of chickens. The Animal Welfare Act (2006) recognises 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)).

28. UK Broiler Welfare guidance includes the five freedoms, yet 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 in factory farms are subject to overcrowding and stress, and broiler breeders are also subject to painful mutilations (beak clipping), which leads to immense suffering. Undercover investigations show that animal abuse, sickness, and extreme suffering is commonplace on factory farms, even those labelled Red Tractor and RSPCA Assured. The application does not meet the welfare guidance of the five freedoms as required by s9(2)(c) and (e) of the Animal Welfare Act. 

Kind regards,

Sources  

1.     https://bryantresearch.co.uk/insight-items/big-ag-lie/

2.     https://elflaw.org/news/landmark-legal-victory-for-englands-rivers-the-court-of-appeals-pickering-judgment

3.     https://www.gov.uk/government/news/lack-of-water-presents-existential-threat-says-environment-agency-chief

4.     https://www.nature.com/articles/d41586-025-00245-6

5.     https://plantbasedhealthprofessionals.com/wp-content/uploads/2025/03/PLANTS-FIRST-HEALTHCARE-REPORT-1-1.pdf

6.     https://environment.data.gov.uk/catchment-planning/v/c3-plan/OperationalCatchment/3278

7.     https://www.foodfortheplanet.org.uk/muck-map/

8.     Antibiotic overuse:

9.     https://www.saveourantibiotics.org/the-issue/antibiotic-overuse-in-livestock-farming/; https://pmc.ncbi.nlm.nih.gov/articles/PMC6017557/

10.  Bird flu:

11.  https://www.sciencedirect.com/science/article/abs/pii/S1473309924002342; https://www.thelancet.com/journals/laninf/article/PIIS1473-3099(24)00438-9/abstract

12.  Nutrition / Health:  https://www.pcrm.org/good-nutrition/nutrition-information/chicken

13.  Cancer: https://pubmed.ncbi.nlm.nih.gov/40284233/

14.  Animals:

15.  https://ourworldindata.org/data-insights/billions-of-chickens-ducks-and-pigs-are-slaughtered-for-meat-every-year

16.  The planet:

17.  https://ourworldindata.org/food-choice-vs-eating-local; https://pmc.ncbi.nlm.nih.gov/articles/PMC9024616/

18.  https://en.fvm.dk/news-and-contact/focus-on/action-plan-on-plant-based-foods   

19.  https://environment.data.gov.uk/catchment-planning/v/c3-plan/OperationalCatchment/3278

20.  https://www.foodfortheplanet.org.uk/muck-map/

21.  https://www.greenpeace.org/static/planet4-international-stateless/2021/04/b1e486be-greenpeace-international-report-destruction-certified_finaloptimised.pdf?_gl=1*b1gm61*_up*MQ..*_ga*NTk5MjA0NTQuMTc0NjU2MTc2MA..*_ga_94MRTN8HG4*czE3NDY1NjE3NTkkbzEkZzAkdDE3NDY1NjE3NTkkajAkbDAkaDU4NDAzMTA4MA..

22.  https://en.milieudefensie.nl/news/10-reasons-why-certification-should-not-be-promoted_june-2022.pdf

23.  https://www.bailii.org/ew/cases/EWCA/Civ/2019/888.html

24.  https://www.ciwf.org.uk/our-campaigns/factory-farming-map/

25.  https://www.statista.com/statistics/316321/poultry-meat-export-value-in-the-united-kingdom-uk/

26.  https://ahdb.org.uk/news/analyst-insight-in-a-flap-about-poultry-feed-demand

27.  Food in the Anthropocene: the EAT-Lancet Commission on healthy diets from sustainable food systems. https://pubmed.ncbi.nlm.nih.gov/30660336/

28.  https://www.gov.uk/government/publications/poultry-on-farm-welfare/broiler-meat-chickens-welfare-recommendations

29.  https://www.ciwf.org.uk/media/5789269/laying-hens-reducing-the-need-for-beak-trimming.pdf

30.  RSPCA Assured: Covering up Cruelty on an Industrial Scale  https://www.animalrising.org/_files/ugd/ead451_3e9d75f915814cae8cf9ebb298ee9ba1.pdf

31.  https://viva.org.uk/red-tractor-overview/

32.  https://www.ciwf.org.uk/news/revealed-shocking-rise-in-us-style-megafarms-across-the-uk/

33.  https://www.statista.com/statistics/316321/poultry-meat-export-value-in-the-united-kingdom-uk/