Good Riddance to UK Mega-Dairy
Why a New Proposal Can’t Make the Grade Either
Food & Water Europe welcomes the news that plans for a mega-dairy of 8,100 cows in Lincolnshire have been withdrawn. The grave legal, ethical and economic objections raised during the permitting process are so serious that addressing the “technical issues” could not possibly make this fundamentally flawed approach acceptable enough to proceed.
The model of industrialized dairy production originated in the United States, where the dairy industry has been transformed from small and mid-sized operations to mega-dairies with as many as 10,000 cows. Industrial sized dairies crowd cows into high-density feedlots with no access to grass and milk them in round-the-clock shifts. The waste from these animals ends up polluting local waterways and creates a stench that diminishes the quality of life for the entire community.
The shift to mega-dairies has in the long run not benefited rural communities economically. The trend towards larger operations has caused family farms to disappear. Between 1997 and 2007, an average of 5,000 dairy farms were lost annually, for a total loss of more than 53,000 dairies in a decade.
At the same time that small dairies were being closed, milk production remained constant, with the majority of U.S. milk being produced on large dairies. Meanwhile, as a result of consolidation in processing and distribution, the price that dairy farmers receive for their milk over the last decade has fluctuated widely. But, for most years, the price has been near or even below the cost of production for the milk, while the cost of fuel, labor and veterinary services has continued to rise.
Additionally, building a giant dairy farm in Lincolnshire will set a precedent for developing other industrial style dairies. This trend will not benefit family farmers or consumers. Consumers want to know that their milk has been produced using the most environmentally and humane methods possible. Large dairies by definition do not meet this standard of sustainability. Large dairies are not what Lincolnshire, or the UK as a whole, should be moving towards.
Many other issues of critical concern were elaborated in documents submitted to the planning authority. They include:
1) Potential problems with the water supply
Anglian Water says, “There is no significant water infrastructure within two kilometers of the site. There have been no details provided regarding water supply and connection.” This is astounding, particularly in light of the facts, as stated by advisors Landscope Land and Property, that water consumption will be high, particularly in the summer. They state provision of water “will be absolutely crucial” to the success of the business and that “the reliability of a supply of fresh water must be absolute,” not least for animal welfare.
2) Potential for water contamination
Again, Anglian Water has “serious concerns regarding the potential impact on the underlying aquifer and would not wish to see any activity in the catchment area of the Dunston source that would result in a further deterioration of the water quality.”
Worse still, the Environment Agency position is to “object to the application as submitted because the applicant has not supplied adequate information to demonstrate that the risks posed to groundwater can be satisfactorily managed.” This is particularly worrying given that Parkham Farms has already been ordered to pay fines and costs for previous contamination of watercourses near other operations.
Furthermore, we cannot understand how evaluation of this proposal can proceed given the lack of information about how the pipeline for slurry management is to be constructed. We note that Natural England’s submission says, “Following discussion with yourself, we understand that, should your authority be minded to grant planning permission for the dairy, appropriate conditions will be enforced which mean the development of the dairy unit will not commence until planning permission for the pipelines has been granted.” However, we do not accept that this proposal can be granted, or even considered, without access to detailed information on all aspects of waste management.
3) Wider environmental impacts
The Environmental Impact Statement (EIS) was not submitted until some considerable time after the plans were offered for consideration. While we hope this does not imply the degree of concern and attention the applicants intend to give environmental issues, we are deeply concerned by the comments submitted by Environmental Health: “There is in general a lack of detail or supporting evidence within the EIS….This means the potential impacts have not been adequately assessed, and as such it is impossible to comment on whether the development can go ahead without causing detriment to nearby sensitive receptors.”
We share a wide array of concerns and objections voiced by other organizations about serious problems with the proposal, including these from:
Lincoln Red Cattle Society and the Bat Conservation Trust about protection of species with special status and legal protection.
Tree Officer about the failure of the plan to take affected trees into account, to provide an appropriate survey or to calculate root protection areas.
Heritage Trust of Lincolnshire, which has voiced concern that “The site is currently subject to an archaeological evaluation. This application should not be determined until the results of the survey are made available.”
The Lincolnshire Wildlife Trust, which has “serious concerns” and objects due to “potential impacts on protected or important habitats or species directly through the construction of the dairy units and associated infrastructure and indirectly through pollution from run-off and ammonia deposition,” as well as the fact that the site is within a Biodiversity Action Plan priority habitat that is “a priority area for calcareous grassland re-creation,” of which there are only an estimated 100 hectares or less remaining in Lincolnshire.
Campaign to Protect Rural England (CPRE) that “there are insufficient intrinsic merits in the application to warrant overriding those material grounds of objection.”
4) Erosion of quality of life for local people
The strong, diverse concerns and reservations expressed by the Parish Councils of Dunston, Branston & Mere, Nocton and Potterhanworth raise urgent questions about noise (especially at night), loss of air and water quality (especially for spring-fed public water supplies) and so on. These are well-founded and serious concerns about potentially significant impacts on human health that will stretch into the future. We wonder if the local residents have been made fully aware of the impacts felt by other communities living near industrial farms, which include:
Babies who drink nitrate-contaminated water run a greater risk of developing the potentially fatal “blue baby” syndrome, where their blood cells lose their ability to carry oxygen.
Several studies have linked nitrates in the drinking water to birth defects, disruption of thyroid function, and various types of cancers.
The long list of other water contaminants including arsenic and other toxic metals, antibiotics, pesticides, and bacterial pathogens lead to an increased risk of E.coli and Camplyobacter infections in areas where manure from nearby livestock operations is applied to farm fields.
Impacts on health from dust particles and toxins from animal feces, hair, feed, and dander, capable of traveling about six miles from industrial animal operations, which can affect white cell blood counts and cause fever and respiratory illness in humans.
Ammonia, methane, and hydrogen sulfide also emanating from animal factories, increasing the risk of skin and eye irritation, coughing and wheezing, diarrhea, asthma, nausea, headaches, depression, and sleep loss.
The Highways Authority requested the refusal of the application “as insufficient details have been provided to enable the Highway Authority to validate the proposed traffic data submitted by the applicant,” which supports concerns of local residents.
Sadly, there are conflicts between measures called for to mitigate impacts on residents and wildlife (landscaping must be sufficiently tall to mask buildings, considerate use of lighting, etc.) and the wishes of the police (to ensure no landscaping is higher than one meter “to maintain a clear field of vision around the development,” to illuminate “all vulnerable areas,” etc.) If these are irreconcilable, the residents’ quality of life should be prioritized, which may lend weight to calls for the proposal to be rejected.
We support the CPRE conclusion that the project “would result in unacceptable damage” to the area with a direct impact on local residents which, as they point out, “appear[s] to conflict with key policies” in the local and government planning policy.
5) Economic considerations
Much is made of the economic “benefits” the scheme would provide. We note the Economic Development Community Services supports the application, accepting claims it will create jobs in a deprived area, but it fails to look at what will be lost or to assess the reality of these promises:
The applicants state, “There will be about 85 staff employed by the dairy and there will also be opportunities for local contractors especially during the construction phase” (source: www.noctondairies.co.uk). However, by our count the applicants’ document, “Economic Development and Business Support” offers around 40 construction jobs which, while welcome, will obviously not provide lasting employment or benefit. Only 27 positions “will be directly involved with milking cows” when fully operational. The document also promises “direct employment of between 50 and 60 local people” in administrative, driving and other posts, but it is unclear how the applicants intend to limit applications to local people while abiding by equal opportunities law. This may have given rise to entirely reasonable concerns of local people that the promised employment opportunities may not be all they seem. The Nocton Parish Council, echoed by Branston & Mere Parish Council, even says that “The proposers now say that many of the 85 jobs will probably not be taken up by local people due to a shortage of dairy skills in this area, which effectively removes one positive factor of the application.”
Several submissions cite new opportunities for local ancillary suppliers (from fodder and sand provision to tools). The applicants say, “Forage for the cows will be produced by a co-operative of local farmers” (source: www.noctondairies.co.uk). Yet the Economic Development document they submitted actually offers “opportunities to compete for supply contracts,” which is rather different. We do not see in this document how the applicants intend to, or can, restrict tendering to local operations.
The document states, “The unit will also bring work to local businesses and trades” doing replacement and maintenance work, but again how this will be effectively delivered is not clear.
Overall, we do not see why the people and businesses in the Nocton area should feel confident that they would necessarily benefit economically from the dairy. We also wonder how robust any such relationships will be if Nocton Dairies decides not to restrict its procurement to local suppliers, particularly if their business plan does not play out as predicted and they must look for ways to make savings elsewhere. We think it unlikely the Council can either make these conditions of granting planning permission or enforce them in the future, so there is little reassurance in such promises.
The Economic Development Community Services submission says, “It is difficult to calculate the value of indirect benefits to local businesses, suffice it to say that an enterprise of this scale has the potential to make a significant difference to local shops, pubs and services.” Given the above, this is unrealistically hopeful, especially for the long term. We suggest that, for example, tourists who may have considered visiting the area and frequenting these businesses are in fact likely to be dissuaded when the impacts of smell, noise, traffic and disturbed vistas begin to bite after the disruptive construction period. Indeed, we have already seen comments made that people who have visited the area repeatedly over many years will not return if the dairy goes ahead.
More widely, the confinement technologies employed in industrial animal production progressively decrease the need for workers. They contribute to loss of agricultural jobs and consolidate ownership into the hands of increasingly large companies away from farmers and their communities.
The argument that such an operation is “needed” to exploit economies of scale because smaller operations cannot stay in business is seriously flawed at best. It is the shift toward such industrial operations that is pushing smaller farms out of business. If farm gate prices do not enable smaller farms to succeed, it is because their buyers (notably supermarkets) have so badly distorted the market that they are no longer serving either producers or consumers. If supermarkets ceased selling milk as a loss leader, consumers would have a truer idea of the value of what they consume, and farmers would not be under pressure to sell at less than the cost of production. Plans such as this contribute to the problem, not the solution.
Overall, any such proposal risks creating a ghost town, regardless of any economic “gains” that may appear on paper.
6) Questionable quality of life for housed workers
Comments from the conservation officer about the proposed new “workers dwellings” show that, “The proposed buildings are to be constructed in an isolated countryside location and will not form part of any community or existing group of buildings.” This clearly underscores that neither the dairy nor its workers are likely to be an integrated part of Nocton or its environs. Given the level of public objection to the plan, we wonder if this “us and them” set up is wise.
Detailed analysis of how economic, health and animal welfare realities have played out for farms in the U.S., including full references, can be found in our publications Dairy 101 and Turning Farms into Factories, attached and available at our website.
7) Animal welfare concerns
In addition, we also strenuously object to such plans on animal welfare grounds. While we recognise such issues may fall outside the scope of the consideration of planning authorities, judging from the large number of objections lodged to the planning process on these grounds they are clearly of considerable public concern and must be addressed somewhere.
We are extremely concerned at reports (supported by information from Defra) that the lead applicant in this initiative pled guilty in 2005 to four charges related to administering unlicensed veterinary medicines illegally imported from Ireland. This does not reflect well on assurances that animal welfare and “best practice” in the business will receive the highest consideration. At the time of writing, 172 MPs have signed EDM 1037 opposing the plan, a high level of attention and very quickly achieved since the EDM was only tabled in early March. The EDM cites EFSA’s 2009 report findings that “breeding for high milk yield is the major factor causing poor welfare to cows” – a fundamental problem with this approach that resting in sand cannot reverse.
This sort of operation is not needed, nor is it wanted. There are better, less risky alternatives that provide higher quality product with a better quality of life for all involved. The withdrawal of this proposal is a welcome development. Any revised and resubmitted plans for a mega dairy will not be able to deal with the fundamental flaws inherent in this approach to food and farming, and should be rejected. The public should continue to press for and support cleaner, greener small and family farms.
Food & Water Europe is a program of Food & Water Watch, Inc., a non-profit consumer NGO based in Washington, D.C., working to ensure clean water and safe food in Europe and around the world. We challenge the corporate control and abuse of our food and water resources by empowering people to take action and transforming the public consciousness about what we eat and drink.
For more information, visit http://www.foodandwatereurope.org
Eve Mitchell, Food & Water Europe, The Black Isle, Scotland
[email protected] +44 (0)1381 610 740
Gabriella Zanzanaini, Food & Water Europe, Brussels
[email protected], +32 (0)488409662