Woodend

Objection Comments

1.      I object to application EPR/LP3229LL/A001, Woodend Poultry Farm
Woodend Ledbury HR8 2RS, to convert a Turkey farm to an intensive poultry unit of 180,000 broilers.

2.    This application 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. The application also constitutes a significant intensification which is a material change of use under section 55 of the Town and Country Planning Act 1990.

3.    The applicant states that ‘no planning application required,’ (Application Duly Making Response 3  LP3229LL - Response 22082025) however it is not possible to reconcile this statement with the requirement for planning permission as a Schedule 1 EIA development.

4.    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.

5.    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, ancient woodlands, SAC/SSSIs protected sites, the climate, rivers must all be assessed.

 6.    There are 17 sensitive receptors, including 14 houses, under 400m away from this site; odours and air pollution in the form of ammonia and particulate matter are a very real concern for residents.

7.     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, 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 180,000-broiler unit exceed critical thresholds at nearby ancient woodland sites. Ancient woodland takes hundreds of years to establish and is defined as an irreplaceable habitat.

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 ancient woodlands, unless there are wholly exception reasons, which there are not here.  

11.   The application is therefore contrary to the NPPF.

12.  The Environment Agency should refuse this application.