This comment is made on behalf of East Keal Parish Council.
As the potential development falls within the boundaries of East Keal we request the following items be considered and included in the EIA (Environmental Impact Assessment).
1. Air Quality
A comprehensive air quality impact assessment for the development, including quantification and dispersion modelling of emissions such as ammonia, odour compounds and fine particulates (PM10/PM2.5 and bioaerosols), to assess the likely concentrations at residential receptors and the potential distance these pollutants may travel.
2. An odour impact assessment that:
a) identifies odour sources (ventilation fans, manure/litter storage, land-spreading, vehicle movements);
b) assesses impacts under different weather conditions and wind directions;
3) models odour dispersion to nearby residential properties and sensitive receptors; and
c) includes clear mitigation, monitoring and enforcement arrangements (including a complaints procedure and trigger thresholds)
4. Avian Flu
The proposed development is close to a pond that is home to wildfowl during large parts of the year, which may increase the risk of avian influenza transmission. We request that the applicant include a robust, site-specific avian influenza risk assessment and biosecurity management plan, including measures for prevention, monitoring, and outbreak response.
5. Waterways, drainage and ecological risk
The proposed site is surrounded by waterways, dykes and drainage channels, which raises serious concerns about the potential for pollution and ecological harm from the increased risk of nutrient-rich runoff (nitrogen and phosphorus), contaminated wash water, and accidental spills entering local watercourses, potentially damaging aquatic habitats and biodiversity, requiring a comprehensive assessment of impacts on water quality and ecology and a robust surface water and pollution prevention plan, including clear mitigation, monitoring and enforceable conditions.
6. Noise Pollution
A comprehensive Noise Impact Assessment that covers both operational noise from the megafarm (including ventilation systems, machinery, generators and loading/unloading) and increased HGV traffic noise on the surrounding road network, including night-time disturbance and predicted noise levels at the nearest homes.
7 Additional potential risks posed by the increase in HGV traffic to the site:
a) highway safety risk (HGVs on a 60mph rural road, turning movements, visibility)
b) amenity impacts in addition to noise (vibration, disturbance)
c) air pollution (diesel particulates / NOx)
d) need for a Transport Assessment + HGV Management Plan
