4. Ammonia modelling Please submit revised modelling, a revised spreadsheet with pig types/numbers and housing details used in the modelling, and respond specifically to the following points: REVISED MODELLING SUBMITTED a) There are currently inaccuracies in some of the emission factors used in the modelling – you state in the spreadsheet submitted 28/06/22 (attached for reference) that house 4 weaner shed contains a total of 990 pigs for 100% of the time, split as 330 pigs 7 – 15kg, 330 pigs in the weight range 15 – 30kg and 330 pigs > 30kg. An emission factor of 0.29 kg NH3/animal place/year has been assigned for each of the 3 weight ranges. This is the emission factor for a deep pit fully slatted system for pigs in the weight range 7 – 15kg. Please refer to the emission factors listed in the attached ammonia screening request form to assign the appropriate emission factors (if it is a deep pit system (slurry depth > 800mm, infrequent slurry removal) then 0.29 NH3/animal place/year is correct for 7 – 15kg pigs, but the emission factors for the 15 – 30kg and > 30kg pigs should be 1.59 and 4.14 NH3/animal place/year respectively. However if the system is not deep pit then an appropriate emission factor should be assigned – please provide more detail for the system in use and submit these in a revised spreadsheet with the assigned appropriate emissions factors as well as incorporating them into the revised modelling. If easier, please call me to discuss this further before submitting revised modelling. EMISSION FACTORS FOR PIGS INCREASED AT EA REQUEST b) Please confirm the weight range for pigs in house 8 (weaner shed) as this hasn’t been confirmed in the spreadsheet submitted 28/06/22. If it is not pigs in the weight range 7 – 15kg then please confirm an appropriate emission factor and incorporate this into the revised spreadsheet and modelling. SIZE IN SPREADSHEET, EMISSION FACTORS FOR PIGS INCREASED c) The pig numbers in your spreadsheet submitted on 28/06/22 total 3072, and the slurry storage is given as 1584.735 m2 in an uncovered slurry store with an emission factor of 1.4 kg NH3/m2/year. The numbers in the spreadsheet for the modelling you supplied on 20/06/22 (also attached for reference, titled ‘PIGS emission calcs v2’) total 3112 and the slurry storage includes an additional uncovered slurry lagoon with the same amount of slurry 1584.735 m2 and an emission factor of 0.56 kg NH3/m2/year, which is the emission factor for a floating cover. Please explain the discrepancies, complete the revised spreadsheet with the correct numbers and ensure the modelling reflects these numbers. CLARIFIED IN REPORT. EXISTING LAGOON IS UNCOVERED d) You have stated in your spreadsheet received 28/06/22, that occupancy is 100%. We would expect some downtime for clean out between batches. Please provide justification for 100% occupancy, or specify the % reduction that should be applied for each pig type in each shed (based on the number of days empty per year) and ensure this is incorporated into revised modelling (standard pig emission factors are based on 100% occupancy, whereas the broiler emission factor takes downtime in to consideration). MY UNDERSTANDING IS THAT SCAIL FACTORS FOR PIGS AND POULTRY ARE ALREADY FACTORED (HENCE NO OPTION FOR 'DAYS' AS IS THE CASE FOR CATTLE AND LAGOONS ETC) e) An incorrect emission factor has been used for broilers; 0.03 kg NH3/animal place /year has been used rather than the emission factor of 0.034 kg NH3/animal place /year. Please ensure the revised modelling incorporates the standard emission factor. THIS WAS TAKEN FROM THE OLD AQTAG BUT NEW FACTORS AND CALCULATIONS CLARIFIED IN THE REPORT AND SPREADSHEET. f) For the modelling of the pig sheds, each shed has been considered as a single point source. We do not consider this to be in line with our guidance which recommends use of a volume source where there is natural ventilation. Please ensure revised modelling includes these as volume sources. VOLUME SOURCE PROVIDES HIGHER BASELINE RESULTS THAN POINT HENCE THE SELECTION OF POINT WITH NO EFFLUX ORIGINALLY. CHANGED TO VOLUME AS REQUESTED. g) There are two nearby farms identified which could be acting in-combination (Hall Farm and Barn Farm) and source characteristics are presented within the poultry emissions calculations but these sources have not been modelled. At this stage we would not look at the in-combination effects for a betterment proposal. If we agree the application can be duly made and we carry out a more detailed assessment we will consider any in-combination effects then, and we may also need to consider other plans and permissions, besides permitted intensive farms. IN-COMBINATION SECTION REMOVED AS REQUESTED. h) The titles of sections 4.4.3 (‘Results: Critical Levels’) and 4.4.4 (‘Results: N Nitrogen Critical Load’) are misleading – these sections appear to present the process contributions for ammonia and nitrogen deposition in tables 4-6 and 4-7 respectively, and do not compare results against the relevant critical levels and loads for each nature conservation site. However, we will do this during our more detailed assessment for the poultry unit, when I have confirmed appropriate critical levels for specific sites. AS IT IS A BETTERMENT I DON'T SEE WHY THIS IS NECESSARY, BUT % OF LIMIT COLUMNS ADDED FOR COMPLETENESS. i) The report results do not include reference to the specific names of the sites which require a Habitat Regulations Assessment, however there are results for the overlying SSSIs, for instance ER15 is Blo’ Norton and Thelnetham Fens SSSI and overlies Waveney and Little Ouse Valley Fens SAC. Similarly Breckland Forest SSSI overlies Breckland SPA and Redgrave & Lopham Fens SSSI overlies Redgrave & South Lopham Fens Ramsar. THESE REMAIN IN TABLE 4-1. j) The emission rate in table 4-5 of the modelling report appears to be inconsistent with the poultry emission rate within the model files and poultry emission calculations. Please provide the calculation for this and ensure the correct emission rate is incorporated into the revised modelling. CALCULATIONS INCLUDED IN THE SPREADSHEET AS WELL AS THE REPORT. Please note: whilst we will take into account the reduction in emissions from the site (as a ‘betterment’ proposal), we will also be comparing the impacts from your proposed broiler unit against the ammonia screening thresholds given in the guidance for the risk assessment of the impact of ammonia emissions at Intensive farming risk assessment for your environmental permit - GOV.UK (http://www.gov.uk) and take into account the additional assessment as described in the attached document (IRPP External note on interim process June 2021’). THE PLANNING (AND PERMITTING) APPLICATIONS SHOULD BE VIEWED AS BINARY PROCESSES, EITHER THEY ARE REFUSED OR APPROVED. IF THEY ARE REFUSED AND THE PIGGERY CONTINUES THE IMPACTS ON THE ECOLOGICAL SITES WILL BE WORSE THAN IF IT IS APPROVED. AS THE BASELINE SHOWS THAT THE EXISTING LEVELS AT THE EUROPEAN SITES ARE ABOVE THE LIMITS, SURELY IT WOULD CONFLICT WITH THE HABITATS REGULATIONS TO NOT APPROVE THE SCHEME AND BRING ABOUT THE REDUCTIONS / IMPROVEMENTS?