Response 647207082

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4. Please provide your comments on the environmental permit application received from Newcome-Baker Farms Limited

Please provide your comments on the environmental permit application received from Newcome-Baker Farms Limited (Required)
In your letter to the Borough Council of King's Lynn and West Norfolk you state that ‘The site is considered to be of high sensitivity and could present potential pollutant/contaminant linkages to controlled waters’. And, ‘without these conditions, the proposed development on this site poses an unacceptable risk to the environment and we would wish to object to the application’. You then list the conditions. As this site is on a slope leading towards the boreholes of Anglian Water and to the Heacham River, and the site will be ‘managed’ by just two workers, I would suggest the risk of contamination is greater than any mitigation the conditions might provide. Accidents happen, that is why they are called accidents; faults occur in systems; human error is difficult to design out. If Anglian Water’s sources become contaminated then their systems might cut in before the public notice. If the Heacham River is contaminated all life within it will be adversely affected for a very long time – the flow is low and contaminants are not easily flushed out. The Heacham River is recognised by the Environment Agency as an important chalk stream and money and time is being spent improving it. The possible contaminants include 1200 litres of oil; 12000 litres LPG; 875 litres biocides; 45kg rodenticides, 20 litres insecticides (all for one cycle of operation I believe). The last three of particular concern if they leach into the soil and water on site or off site (litter is intended to go on the land). The rodenticide is presumably to kill rats; what precautions are there to stop dying rats being eaten by wild predators such as barn owls which live in the area? And what would be the effect of biocides and insecticides entering the Heacham River. I suggest the healthy count (for example) of shrimp, olives and caddis fly would seriously decline and this would have adverse effects on the fish population including eels. Data about life in the Heacham River can be found on the Rivers Trust Website. I am of the personal opinion that the site will not have the personnel, time, or resources to ensure that the demanding conditions specified in your letter are met in a practical sense, checked before installation or use, or monitored for effectiveness over the life of the unit. There is no scope for an event of ‘low probability’ so the risk posed by this unit on this site is too high. The only option is to remove the risk. I urge the Environment Agency to reconsider its position and not grant a licence for this poultry unit.