Compassion in World Farming                            ESH0072

Written evidence submitted by Compassion in World Farming

Environmental Audit Committee – Call for Evidence: Environmental sustainability and housing growth

1. Compassion in World Farming (Compassion) is the world’s leading farm animal welfare environmental charity. We are headquartered in the UK, and have offices in 12 countries. Compassion’s mission is to end factory farming and create a world where farm animals are treated with respect and compassion. In working towards this mission, Compassion works to address the impact of the intensive livestock farming system on the planet and humans, as well as the more than one billion farmed animals confined in the UK system every year. Formed in 1967, Compassion has worked on food and farming issues for almost 60 years. 

2. In the last year, one of Compassion’s main focusses has been on the externalities of intensive livestock farming - including the pollution from agriculture. These are the costs that arise from factory farming that society pays for, such as river pollution from animal manure and slurry.

3. Compassion welcomes the Environmental Audit Committee’s call for Evidence on Environmental sustainability and housing growth and the chance to submit a response. We believe that the planning system is an important tool in curbing the spread of intensive livestock farming and opening routes to more sustainable agriculture.

1. What provisions will the National Policy Planning Framework, as revised under the Government’s proposals, make for protection and enhancement of the environment? Are these provisions likely to be adequate?

4. Compassion doesn’t consider the current provisions are adequate to protect and enhance the environment. To deliver this the National Policy Planning Framework (NPPF) needs to have a broader focus that includes construction in the farming sector. To protect and enhance the environment it must include the cumulative external costs – externalities – of these activities such as pollution of the land, water and air.

5. Food production and land use is the leading cause of biodiversity loss in the UK,[1] the top polluter of our rivers and freshwater bodies[2] and in 2021 the food system, including emissions overseas from the food imported to the UK, emitted the equivalent to 35% of the UK’s total greenhouse gas emissions.[3]

2. What policy levers does the Government plan to use to ensure that local authorities deliver the development which the revised NPPF ‘standard method’ requires? Do the Government’s plans result in local planning authorities being penalized if delivery falls short? What policy levers will be available to local authorities to ensure that developments which have received planning approval are delivered in accordance with consents?

3. To what extent is the current planning presumption in favour of sustainable development compatible with the environmental objective of the planning system? To what extent will the proposed ‘streamlining’ of the sustainable development presumption work to deliver developments which will meet this objective and be compatible with the Government’s environmental targets and obligations?
   
    

6. The UK is one of the most nature depleted countries in the world. Soils in every region in England are in nitrogen surplus,[4] some receive more than twice what they can absorb.[5] Only 14% of rivers in England achieved ‘good ecological status’ – the criteria for good river health.[6] The Government and Environment Agencies own figures estimate suggest agriculture accounts for between 61-70% [7] [8] of total nitrogen in river water in England and Wales

7. We would suggest there is not a true presumption for sustainable development if planning applications from farms are not included in the NPPF. This is especially true for intensive livestock production units, or factory farming - because of its wide-ranging impacts on the landscape.

8. In 2024, Compassion in World Farming highlighted the expansion of factory farms and megafarms across the UK.[9] The data showed there had been a 12% rise in the number of factory farms and a 20% increase in the number of US-style megafarms – the largest-scale intensive units – compared with 2016 figures previously obtained by Compassion.

9. Currently in the UK, local planning authorities are unclear whether they can take animal welfare and environmental issues such as river pollution and climate change into account when considering planning applications for factory farms. As a result, they have been unable to contain their spread and have failed to halt damage to our countryside, climate, and the health of communities.

10. Compassion believes that the NPPF should make it beyond doubt that climate change and animal welfare are material considerations in every single planning decision. This will ensure that where the local environment or communities are overwhelmed by factory farms, local authorities can reject planning applications for even more of them.

11. Additional research commissioned by Compassion, Sustain and Friends of the Earth, published in November 2024, showed the quantity of slurry and manure produced by chicken and pig factory farms every day in the UK – 33,450 tonnes.[10] This is driving nitrogen pollution, damaging protected areas [11] and affecting local communities. The research showed the river catchments that are most at risk from agricultural pollution; the top three river catchments are the Severn, Great Ouse, and Ouse (Yorkshire).

12. If the intensive livestock industry expands at its current rate, annual nitrogen production will be up 32% on 2016 levels by 2028[12]. With the construction of 100,000 homes already affected by nutrient pollution[13], unchecked intensive livestock expansion could threaten the government’s target to build 1.5 million homes by the end of this parliament.

13. Any further expansion of intensive livestock farming in the UK is a threat to climate change, with the Committee on Climate Change recommending a 20% reduction in UK meat consumption by 2030. [14]

14. The Government should adopt the recommendations of the previous Environment Audit Committee’s (EAC) Environmental change and food security report.[15] The EAC recommended that the Government adopt a presumption against granting planning permission for new intensive livestock units in polluted catchments, through national planning policy, by:

• “Establish[ing] a presumption against granting planning permission for new intensive livestock units where the proposed development would exceed the catchment’s nutrient budget, unless there are more robust mitigations in place.”

15. As a minimum, the presumption should apply in all catchments where nitrogen budgets are exceeded, and design support packages to incentivise farmers to adopt sustainable farming models.

4. How will the revised NPPF work to deliver the social and environmental objectives of the planning system? To what extent will it promote outcomes which deliver sustainable social and environmental benefits together, such as access to essential amenities, to public transport and to active travel routes?

16. Compassion is concerned that rural communities are in decline because of the lack of good sustainable job opportunities.[16] This is, in part, being driven by intensive livestock farming - both in the growing of grain to feed the animals and in the intensive livestock production units themselves. A recent study of farming jobs in the EU between 2007 and 2022, which included arable farming, highlighted farming jobs decreased by 38% with small-scale farms hit hardest.[17] With less people it is increasingly uneconomic to provide essential services in these communities.

17. Intensive Livestock Units typically create few jobs, cost the taxpayer tens of millions in subsidies and compensation and harm other business sectors.[18] [19] [20] Whilst profits for many UK farmers are falling, agribusinesses’ profits are growing.[21]

5. What contribution can the NPPF make to meeting Government targets for the reduction of greenhouse gas emissions? What account does the NPPF take of advice from the Climate Change Committee on reducing the use of embodied carbon as well as operational carbon in the built environment?
    
6. Will the Government's proposals affect the ability of local authorities to implement policies designed to protect the natural environment in their areas?

18. We do not believe so. In its current form we believe there will not be sufficient focus on the true cost of planning applications for intensive livestock units. 

7. What (if any) trends are observable in (a) delivery of environmental improvements (b) the purchase and trading of credits arising from the Environment Act requirement for developments to yield biodiversity net gain (BNG)? How are planning authorities using BNG in the planning process to deliver environmental improvements from housing development?

8. How will the revised NPPF operate to promote the Nature Recovery Network and the implementation of local nature recovery strategies by responsible authorities?

9. What use can planning authorities make of the data analysis and modelling being developed under the National Land Data Framework to support planning decisions which lead to better environmental outcomes? How should the NPPF be integrated into the forthcoming Land Use Framework?

10. What environmental regulatory arrangements within Defra’s remit which relate to the planning process are likely to be under review as potential inhibitors of growth? What effect on environmental protections would reform of these regulations be likely to have?

December 2024