Wrights Farm

Objection comments

I object to application EPR/SP3825ME/A001 for an environmental permit to rear 265,000 broilers on a new greenfield site, in 6 poultry houses with LPG heating. The application is for Wintercrack Ltd, at Wrights Farm, Side Bar Lane, Heckington Fen, Sleaford, NG34 9LZ.

The proposed total number of chickens confined for meat production is approaching 2 million every year.

The proposed intensive poultry unit is for chicken places in excess of 85,000 and therefore requires a full Environmental Impact Assessment (EIA) 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 applicant wants to build a new installation on a greenfield site, comprising:

- 6 poultry sheds of unspecified dimensions

- 11 bulk feed silos

- An attenuation pond

- Underground dirty water storage tanks

- Carcass storage

- Generator housing

- LPG storage tanks

- Boundary fence and collision barriers

- Chemical store

- Gatehouse

- Concreted yards and working area of unknown size.

This represents a substantial intensification of land use and the applicant should be required to obtain planning permission before the Environment Agency (EA) grants a permit. This situation emphasises the reason for the requirement to “twin track”; allowing the permit without planning permission risks enabling the development without a full Environmental Impact Assessment. We therefore urge the EA not to grant a permit before the application has planning permission.

The application’s assessment of emissions is undermined by several inconsistencies and inaccuracies. The Application Form, Site Condition Report, Noise and Odour Assessments claim there are no sensitive receptors within 400 metres of the site. However, the Technical Standards document explicitly states in the Noise and Vibration section: "There are neighbours (sensitive receptor) within 400m of the farm". Under Environment Agency guidance, written management plans are mandatory if receptors are within 400 metres. If neighbours are present, the absence of these plans and the failure to assess specific impacts on these individuals is a major regulatory omission.

The case of R (Squire) v Shropshire Council [2019] EWCA Civ 888 confirmed 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 local planning authority (LPA) does not need to rely on the farming rules for water if they are not working. Ammonia emissions arising from manure are a serious concern. Manure production and its subsequent off-site spreading are an unavoidable by-product of intensive poultry operations, but the application’s manure management plan is undermined by contradiction and lack of detail. While the Non-Technical Summary and Technical Standards explicitly state that "litter is not stored at the installation" and is removed immediately following depopulation, the Fugitive Emissions assessment directly contradicts this by describing the management and pesticide treatment of "temporary field heaps". Ammonia emissions are heavily influenced by how manure (litter) is handled. If temporary field heaps are located within the installation boundary, their ammonia emissions must be quantified as part of the total site emissions. If they are off-site, the application fails to clarify their location or the potential for cumulative ammonia impacts in the immediate vicinity of the farm. The application relies on a pre-application simple screening to conclude "little likelihood of impact to nearby wildlife sites", but it does not provide the specific results (such as the percentage of Critical Level or Critical Load) for the sites screened. Without seeing the actual screening data, it is impossible to verify if the farm’s emissions truly fall below the thresholds that would otherwise trigger mandatory detailed atmospheric dispersion modelling. The applicant proposes to reduce ammonia emissions through a nutritional strategy that lowers nitrogen (N) and phosphorus (P) in the birds' feed. However, the application lacks specific targets for crude protein reduction. BAT 3 requires adaptation of the diet to specific production periods. Without specified protein levels or a defined "multiphase feeding" schedule, the regulator cannot verify the claimed reduction in the "nitrogen excreted" values, which are used to calculate ammonia emissions. A robust assessment of ammonia emissions is particularly critical given the site's location in Flood Zone 3 and a Surface Nitrate Vulnerable Zone, where the presence of uncontained heaps would significantly elevate the risk of contaminated runoff entering nearby watercourses, such as Head Dike, during “likely” flood events. Furthermore, the plan lacks robustness in its export strategy; although contingency arrangements are in place with "surrounding farms" to accept manure in an emergency, the applicant fails to provide named recipients, signed agreements, or a formal assessment of receiving land suitability (such as soil type, slope, and proximity to watercourses) as required by Best Available Techniques (BAT) 20. Instead, the plan relies on third-party receivers signing a “docket" to claim compliance with good agricultural practice, shifting regulatory responsibility rather than demonstrating a proactive, operator-led strategy to prevent environmental pollution.

Recent cases have placed stringent obligations on factory farming developments. 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 the production of animal feed, slaughter, packaging, transport, and sale, which are indirect and consequential effects that are an inevitable consequence of the permitted activity. This omission prevents compliance with the Environmental Permitting (England and Wales) Regulations 2016.

The case of R (Caffyn) v Shropshire Council [2025] EWHC 1497 (Admin) directly considered intensive poultry units, and confirms that the planning authority should assess the cumulative impacts of having multiple intensive agricultural developments in one river catchment before granting permission for another. The wastewater management plan for the Wrights Farm application is technically inadequate due to its heavy reliance on manual mitigation and the failure to account for the installation’s high-risk environmental setting. The drainage system depends on the manual placement of "diverter bungs" during wash-down periods to prevent contaminated water from entering the clean water system. This creates a significant risk of human error, which is compounded by the fact that the clean water system terminates in an unlined attenuation pond. Because the pond is unlined and the site is located just 283m from Head Dike in Flood Zone 3 - where the applicant admits flooding is "likely" - any accidental discharge of wash water containing toxic spent disinfectants (such as Formalin) could result in the direct contamination of groundwater or local watercourses. Furthermore, the plan lacks robust engineering failsafes; there are no automated high-level alarms for the underground dirty water tanks, with the applicant relying instead on manual monitoring to maintain a mandatory 300mm freeboard during high-volume pressure washing. Most critically, the application fails to provide volumetric estimates of the wastewater generated per cleaning cycle for the six poultry houses. Without this data, the regulator cannot verify if the proposed underground tank capacity is sufficient to prevent overflows, undermining the applicant's conclusion that the overall risk of water contamination is "not significant". The installation will be using water for both consumption and cleaning out of the 6 sheds, 7- 7.5 times per year, but neither source nor the volume are specified. Under the Water Framework Directive, water bodies must not deteriorate in status, therefore the applicant should provide full assessments of:

- the total nutrient contributions,

- the cumulative effect with other IPUs in the Anglian River Basin,

- the volume and source of water required by this installation.

Without this information the Environment Agency cannot rationally conclude that further deterioration or threat to drinking water supply will be avoided.

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 chickens in factory farms due to both their fast-growing genetics and cramped, crowded housing. A European Food Safety Authority 2023 report recommended a maximum stocking density of 11kg/m2 to give broiler chickens sufficient space to express their natural behaviours and support their health, but the applicant gives no details about stocking densities or environmental enrichment. Chickens are known to have a useful sense of smell and are therefore likely to be distressed by the noxious odours inside the sheds. Additionally, chickens are social beings, intended to live in small groups; when forced into large, overcrowded conditions they suffer stress from the breakdown of their natural social order. The applicant should give full details of the proposed stocking density and the enrichment provision for the chickens.

Failure to assess the full implications from feed poses a direct threat to UK national security. Increasing demand for soy for feeding farmed animals is a primary driver of deforestation, accelerating the global biodiversity loss that HM Government identifies as a threat to national security, and deepening an unsustainable dependency on imported South American soy, which already constitutes 18% of produced UK animal feed. Such developments exacerbate cascading risks - including geopolitical instability, resource competition, and interstate conflict - whilst also heightening pandemic risk from zoonotic disease through the overcrowding of domestic poultry, highlighting the need for robust pandemic preparedness. Because the UK lacks sufficient land to simultaneously rear livestock at current scales and feed its population, national resilience necessitates a wholesale change in consumer diets toward the predominantly plant-based Planetary Health Diet rather than the expansion of intensive units that lock the nation into fragile international supply chains. Similarly, the UK Climate Change Committee advises a 25% reduction in total meat consumption by 2040 to meet climate and health targets. Therefore granting of permits to produce more meat is in direct opposition to recent scientific and Government reports.

Intensive poultry production represents an inherently inefficient use of grain protein. Of 100g of grain protein fed to chickens, only 34g is converted to edible protein. Since the grain could have been fed directly to humans, this represents an environmentally disastrous and unsustainable process which does not support local, national or global food security and sustainability goals. Furthermore, no information is provided regarding the associated environmental impacts of deforestation, soil degradation, air and water pollution caused by pesticides and fertilisers used to increase yields.

The application represents a significant intensification of land use with serious consequences to the amenity of people, public health, the environment, and the animals. Increases in odours, dust, ammonia, pollution, traffic, manure, waste, dirty water, greenhouse gas emissions, and the downstream direct and indirect impacts on people, ancient woodlands, SAC/SSSIs protected sites, the climate, and rivers should all be fully assessed. In addition, the further permitting of activities which are fundamentally misaligned with international, national and local goals and plans intended to protect the climate, biodiversity, food security and public health would be misguided. It is therefore extremely important that no permit is granted prior to planning permission being granted, as the EIA will only be reviewed during the planning consultation process.

The Environment Agency should refuse this application.