NFU Responds to final BREF Document

The NFU has submitted a response to the final draft of the IPPC Best Available Technique reference document (BREF). The review of the BREF document has been ongoing since August 2013 and this was the last opportunity to make any comments.

What is the BREF?

The ‘BREF’ is the European guidance document for the Industrial Emission Directive (formerly IPPC) for the pig and poultry sectors.

It outlines Best Available Techniques (BAT), or best practice, covering a range of activities on farm which must be transferred into guidance (e.g. how to comply) in England and Wales. It is applicable to all permitted pig and poultry units which house more than:

  • 40,000 poultry places;
  • 2000 production pigs (over 30kg); or
  • 750 sows;

It is enforced by the Environment Agency in England and Natural Resources Wales in Wales.

The BREF was last updated in 2003 and is now being revised.

The consultation response was produced in collaboration with other key stakeholders including BPEX, National Pig Association, British Poultry Council and the British Egg Industry Council. Because this is an EU wide document, we have also consulted with the Irish Farmers’ Association and Ulster Farmers’ Union to ensure consistency in response and the best possible outcome from the document.

Piglet_275_183There have been many improvements made to the document since the final Technical Working Group Meeting in Seville in November 2013 which will reduce the practical implications of the document on farms, most noticeably a relaxation in emission limit values. However, as we have stated within out response, there are some improvements which could still be made to ensure that reducing emissions do not have an adverse impact on legitimate business.

Our primary responses were:

  • For the maximum time between the application of manure and slurry to land and incorporation to be increased from 12 hours to 24 hours. The current proposal of 12 hours is already a large improvement on the original suggestion of four hours. However we have argued that the 12 hour incorporation window will bring the spreading into the night which is impractical and infringes on health and safety;
  • For odour and noise modelling to only be required when they cause significant pollution instead of when odour and noise nuisance is ‘expected and/or substantiated’. We have stated that requiring expensive monitoring to be undertaken when the nuisance is only expected is a huge financial burden on farmers and the money is better spent on noise or odour abatement techniques rather than on modelling;
  • We have also asked for the removal of a measure to require odour or noise modelling to be undertaken if a unit has a sensitive receptor a set minimum distance away. We have argued that this is a crude measure and doesn’t take into consideration that the site may be having no impact on the local community regardless of the distance they are aware from the site;

We have continued to iterate that animal welfare cannot be compromised but must not influence the outcome of the BREF, especially the range of housing options available.  Further information on the changes made to the BREF and the NFUs response can be found on the attached spreadsheet or by contacting Martin Rogers at bWFydGluLnJvZ2Vyc0BuZnUub3JnLnVr.

Last edited on: 02:06:2015

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