B&MSDC Supplementary Planning Documents Consultation
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B&MSDC Supplementary Planning Documents Consultation
Draft Intensive Livestock and Poultry SPD Consultation Document - May 2024
Representation ID: 23602
Received: 19/06/2024
Respondent: River Waveney Trust
Thank you for preparing this draft SPD. We welcome this initiative and the opportunity to comment.
Producing this document is a helpful step forward, and will be invaluable in responding to what appears to be a growing number of proposals from this sector. We have prepared our response from the point of view of the health of the river: in particular meaning the quality of the water, the flow of the water, and biodiversity to be found in and along the river and its many tributaries.
Overall there must be a far greater emphasis on rivers and watercourses, and their health and protection, throughout the document. From searching the draft SPD’s contents, ‘water’ appears 77 times, while ‘watercourse’ appears just three and ‘river’ twice. Though in some instances ‘water’ does refer to water quality, whether of groundwater or watercourses, in the great majority of instances it is referring to water resources and the water supply infrastructure network. We understand that water resources are of course essential for the economic development of the area, but in our view this is a very one-sided view of water. It is now recognised that England is facing a biodiversity crises, with over half of species in decline and one-sixth facing extinction (State of Nature report). Freshwater occupies about 3% of the UK’s surface but our rivers contain at least 10% of our species, partly due to the variety of habitat: e.g.: pools, submerged tree roots, sediment, banks, riparian vegetation and floodplains.
All watercourses throughout the catchment are interlinked and the SPD should reflect this. For example at para 2.3, the existing policy LP14 is cited, which refers to ‘sensitive environmental receptors’. In our view, everywhere is in one river catchment or another so at times it may be unhelpful to specifically highlight sensitive areas or those with a higher level of protection. For example an intensive livestock or poultry facility in Bacton, Stradbroke or Eye could have an impact on water quality downstream in Mendham or beyond. We suggest that all watercourses need consideration not just ‘sensitive’ ones.
Sections 5.2 to 5.8 set out a number of subheadings for consideration, including water resources (c) and visual and landscape impacts (f). This would be the ideal place to have a further subsection specifically on the water quality and also water quantity (flow) in rivers. Water quality is referred to in a few places (e.g.: 2.3b, 5.3.1, 5.6.2), but their impact is dramatically lessened by not being in a single coherent section, which would emphasise the need to protect rivers and watercourses. A new section on riverine water quality and quantity would helpfully balance the existing section on water resources. We are happy to provide you with guidance to help you build this section.
Para 5.10.1 discusses the need to consider cumulative impacts resulting from similar developments. This is crucial, but the language here could be clearer and tighter. For example, recently the River Waveney Trust responded to an environment scoping for a proposed poultry processing mill, and a linked second proposal for a reservoir and two pipelines to/from the river. However, the way that proposal is framed makes it almost impossible to assess the total impact of the supply chain, which would be distributed across many (not stated but perhaps dozens) of individual suppliers. Each of these would be subject to its own separate planning application, making it highly challenging for the planning authority to consider the cumulative impact. This is an unacceptable state of affairs and we’d urge you to find the right language and mechanisms to manage this.
Section 5 goes into detail on number of specific types of pollution (noise, air and ammonia / nitrogen). It would be helpful if a section specifically on phosphates could be added, as they are a key nutrient leading to eutrophication. Other authorities have guidance on phosphates, such as Somerset, and this could be adapted for the Suffolk context. Phosphates are mentioned just once at para 5.3.4, and nutrients are mentioned more broadly in a few places, but guidance specifically on phosphates would be a welcome addition here.
We would urge a presumption against any new abstraction from the River Waveney or any of its tributaries, for any purpose, regardless of whether a proposal suggests that the return of treated wastewater would theoretically make the impact on the river flow to be neutral. This should apply to the entire catchment, not just the Hartismere water resources zone. At some times of the year, parts of the Waveney have little or no flow – with significant impacts on wildlife but also on the ability of local people to access and use the river.
We would urge mixed vegetative buffers (not simply grass) be required along all watercourses. We are happy to work with you to develop this section, but for example here is a guidance document prepared for the northwest, the broad principles of which would apply here. A buffer strip is a physical barrier that slows the flow of overland runoff, increases infiltration and prevents soil, sediment and nutrient loss from fields – indeed provide a measure of protection from and adjacent land use. Buffer strips can trap and filter runoff therefore improving the water quality of the river by helping to prevent nutrients, sediments and pesticides from reaching the river. Keeping livestock out of the water protects the banks and channel, and therefore water quality, and also reduces the risk of livestock acquiring waterborne diseases.
Thank you for preparing this draft SPD. We welcome this initiative and the opportunity to comment.
Producing this document is a helpful step forward, and will be invaluable in responding to what appears to be a growing number of proposals from this sector. We have prepared our response from the point of view of the health of the river: in particular meaning the quality of the water, the flow of the water, and biodiversity to be found in and along the river and its many tributaries.
Overall there must be a far greater emphasis on rivers and watercourses, and their health and protection, throughout the document. From searching the draft SPD’s contents, ‘water’ appears 77 times, while ‘watercourse’ appears just three and ‘river’ twice. Though in some instances ‘water’ does refer to water quality, whether of groundwater or watercourses, in the great majority of instances it is referring to water resources and the water supply infrastructure network. We understand that water resources are of course essential for the economic development of the area, but in our view this is a very one-sided view of water. It is now recognised that England is facing a biodiversity crises, with over half of species in decline and one-sixth facing extinction (State of Nature report). Freshwater occupies about 3% of the UK’s surface but our rivers contain at least 10% of our species, partly due to the variety of habitat: e.g.: pools, submerged tree roots, sediment, banks, riparian vegetation and floodplains.
All watercourses throughout the catchment are interlinked and the SPD should reflect this. For example at para 2.3, the existing policy LP14 is cited, which refers to ‘sensitive environmental receptors’. In our view, everywhere is in one river catchment or another so at times it may be unhelpful to specifically highlight sensitive areas or those with a higher level of protection. For example an intensive livestock or poultry facility in Bacton, Stradbroke or Eye could have an impact on water quality downstream in Mendham or beyond. We suggest that all watercourses need consideration not just ‘sensitive’ ones.
Sections 5.2 to 5.8 set out a number of subheadings for consideration, including water resources (c) and visual and landscape impacts (f). This would be the ideal place to have a further subsection specifically on the water quality and also water quantity (flow) in rivers. Water quality is referred to in a few places (e.g.: 2.3b, 5.3.1, 5.6.2), but their impact is dramatically lessened by not being in a single coherent section, which would emphasise the need to protect rivers and watercourses. A new section on riverine water quality and quantity would helpfully balance the existing section on water resources. We are happy to provide you with guidance to help you build this section.
Para 5.10.1 discusses the need to consider cumulative impacts resulting from similar developments. This is crucial, but the language here could be clearer and tighter. For example, recently the River Waveney Trust responded to an environment scoping for a proposed poultry processing mill, and a linked second proposal for a reservoir and two pipelines to/from the river. However, the way that proposal is framed makes it almost impossible to assess the total impact of the supply chain, which would be distributed across many (not stated but perhaps dozens) of individual suppliers. Each of these would be subject to its own separate planning application, making it highly challenging for the planning authority to consider the cumulative impact. This is an unacceptable state of affairs and we’d urge you to find the right language and mechanisms to manage this.
Section 5 goes into detail on number of specific types of pollution (noise, air and ammonia / nitrogen). It would be helpful if a section specifically on phosphates could be added, as they are a key nutrient leading to eutrophication. Other authorities have guidance on phosphates, such as Somerset, and this could be adapted for the Suffolk context. Phosphates are mentioned just once at para 5.3.4, and nutrients are mentioned more broadly in a few places, but guidance specifically on phosphates would be a welcome addition here.
We would urge a presumption against any new abstraction from the River Waveney or any of its tributaries, for any purpose, regardless of whether a proposal suggests that the return of treated wastewater would theoretically make the impact on the river flow to be neutral. This should apply to the entire catchment, not just the Hartismere water resources zone. At some times of the year, parts of the Waveney have little or no flow – with significant impacts on wildlife but also on the ability of local people to access and use the river.
We would urge mixed vegetative buffers (not simply grass) be required along all watercourses. We are happy to work with you to develop this section, but for example here is a guidance document prepared for the northwest, the broad principles of which would apply here. A buffer strip is a physical barrier that slows the flow of overland runoff, increases infiltration and prevents soil, sediment and nutrient loss from fields – indeed provide a measure of protection from and adjacent land use. Buffer strips can trap and filter runoff therefore improving the water quality of the river by helping to prevent nutrients, sediments and pesticides from reaching the river. Keeping livestock out of the water protects the banks and channel, and therefore water quality, and also reduces the risk of livestock acquiring waterborne diseases.
