17 July 2018 | Online since 2003


9 January 2018

Environmental permit warning for single-tier housing


Non-cage egg producers who increase their bird numbers from below to above 40,000 in future may run into problems in obtaining an environmental permit, if they operate standard, single-tier housing systems.

In February of this year, a European ‘Best Available Techniques’ (BAT) document was published which set out the standards that poultry farms would have to meet in order to obtain an environmental permit and to comply with its terms.


Amongst the new requirements is the need for compliance with BAT Associated Emission Levels for ammonia, known as BAT-AELs. In effect, these set a benchmark for determining whether an activity or system can be regarded as a Best Available Technique or not.

The same BAT-AELs apply across the European Union, the actual figures vary according to species and housing systems. For laying hens in non-cage systems, the BAT-AEL range is from 0.02 to 0.13 kg of ammonia per bird place per year. Only production systems in which ammonia emissions are lower than this maximum (i.e. 0.13) are considered to be BAT-compliant for new farms. In this context, ‘new’ refers to any farm which requires an environmental permit for the first time. It therefore includes any established farms which have operated below the 40,000 bird place threshold in the past.


In England, the Environment Agency (EA) sets ammonia emission factors for different species and systems. As above, these are also stated in terms of ‘kg of ammonia per bird place per year’. So long as the EA’s emission factor is less than the equivalent European BAT-AEL, the system will be regarded in England as a Best Available Technique.

For multi-tier non-cage systems, this is the case. Referred to as ‘aviaries’, the EA’s ammonia emission factor is 0.08, which is easily within the above BAT-AEL range.

For single-tier non-cage systems, the situation is different. The European BAT-AEL is the same as before, at between 0.02 and 0.13. However, the EA’s emission factor is substantially higher at between 0.21 and 0.29. On this basis, the single-tier system is not regarded as a ‘Best Available Technique’ for new farms.

New permit application for a farm with single-tier systems
To illustrate the impacts, consider a farm with two existing single-tier houses each stocked with 16,000 birds. No environmental permit is needed because the farm is below the 40,000 bird place threshold.

However if a third house of 16,000 birds is added, then a permit would be needed for the first time and the farm would be treated as a new one. On this basis, the new house could not be a standard single-tier system for the reasons given above. In addition, the two existing single-tier houses would not be considered as BAT for new farms and so they could not be used in their current form. Unless appropriate modifications could be made to them, all three houses would have to be converted to multi-tier systems if they were to continue in use.

If this situation arises, the likelihood is that the EA would allow an existing single-tier house to be operated only on a temporary basis, from the time the permit is first issued until the time when the current flock is depopulated. No subsequent flocks would be allowed, so the house would then have to be suitably converted or otherwise kept empty.

Farms with single-tier houses and an existing environmental permit
If a farm received its environmental permit prior to 21 February 2017, then it is considered to be an ‘existing’ farm. The ‘new farm’ criteria therefore don’t apply and so existing single-tier systems can continue to be used indefinitely – or at least until there is a further revision to the BAT reference document.

Note – proposed changes to permit-related charges
The EA is currently consulting on proposed fee changes for producers in England, which are due to be introduced from April 2018. Large price increases are proposed, both for new applications and for varying existing permits. Industry bodies and others in the poultry sector will be responding to this consultation but producers considering an application may find it cheaper to make their submissions prior to the end of March of next year.


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