
John Truscott from Pryors cottage responded to the Environment agencies draft PERMIT TO POLLUTE.
This is what he has to say!
Re the "Non-technical Summary": the distances between the installation boundary and the named properties have been vastly misrepresented; e.g. [Well] Pryors Cottage is stated to be 230 metres from the site boundary, when it is in fact contiguous with that boundary on all four sides of the property (i.e. a distance of 0 metres). Other distances have been similarly falsified. The true state of affairs is acknowledged in the draft decision document (p.18), but those people who want
to get a quick overview of the planned installation will find in the Summary a misleading set of statistics provided by the applicant and apparently endorsed by the EA. This distortion is, unfortunately, consistent with the general bias of the documentation, which sacrifices objectivity to a servile deference to the applicants' statistical abstractions and unverified claims. Particularly unsavoury is the argument at 4.8. of the draft decision document (pp.30-31), whereby the applicant's
ownership of a piece of land in nearby Sithney parish is advanced as justification to permit excessive nitrate pollution of the installation site. It is noted in the document that not all of the applicant's Sithney holding lies within the NVZ, but no attempt has been made to obtain precision on this question, or to ascertain whether the applicant's widespread use of nitrogen-rich fertiliser has been extended to that piece of land, which would invalidate an already ethically dubious and partisan argument. It is disconcerting to find the EA complicit in a piece of legalistic sophistry which, if the project is authorised, would amount to a license to pollute. Also highly questionable is the dismissive attitude to the problem of excreta deposited on the ranging area. The applicant has proposed to surround the chicken houses with a cordon of bark/woodchips to a width of 3.6 metres, for use by the hens for purposes of excretion, the soiled cordon to be removed every 3 months. Commenting on this, the draft document states (p.31): "This mitigation measure effectively increases the assumed time spent in houses from the worst-case 80%". While this comment is somewhat lacking in transparency, it appears to suggest not only that excretion outdoors but in close proximity to the chicken houses is precisely equivalent to excretion inside the houses (a contention which is clearly open to argument), but also that ranging itself is, if sufficiently
close to the houses, equivalent to staying indoors. The use of the hypothetical ratio of 80% to 20% is problematic, since it is arrived at by a slipshod process of generalisation ignoring variations in weather which might see very large numbers of hens ranging on a fine day, and can hardly, therefore, be termed "worst-case", since far worse cases may easily be envisaged. The document states a refusal on the part of the EA to employ a precautionary approach using "worst-case"
assumptions, and appears to have departed from its own guidelines merely in order to bolster devious argumentation supplied by the applicant.