Poultry Units

April 23 2026

Subject: Objection to Planning Application 26/00770/FUL – Deanery Farm, Station Road, Bampton

Dear Sir/Madam,

I am writing on behalf of the Society for the Protection of Bampton, representing over 300 residents of Bampton, to formally object to planning application 26/00770/FUL for the proposed broiler breeder unit at Deanery Farm.

This objection is made on the grounds that the proposal conflicts with the West Oxfordshire Local Plan 2031 and the National Planning Policy Framework (NPPF), particularly in respect of residential amenity, landscape character, environmental protection, and sustainability.

1. Fundamental Conflict with Policy OS2 – Inappropriate Scale, Type and Impact

Policy OS2 requires development to be:

• Of an appropriate scale and type
• Compatible with its surroundings
• Not harmful to residential amenity

The proposed development is an intensive, industrial-scale poultry operation, comprising very large buildings, extensive hardstanding, and mechanical ventilation systems.

This represents a fundamental and permanent change in land use and character, which is not appropriate in this open countryside location and is incompatible with the surrounding rural environment.

2. Significant Harm to Landscape Character and Visual Amenity (Policy EH2)

The introduction of multiple large agricultural buildings and associated infrastructure would result in visual intrusion and erosion of the open rural landscape. The proposal fails to conserve or enhance the intrinsic character of the countryside, contrary to Policy EH2.

The applicant’s own Landscape and Visual Impact Assessment (LVIA) confirms:

• Significant adverse visual effects during construction and operation
• Impacts only reduce after approximately 15 years
• The change is permanent and irreversible

This is a clear admission of material harm. Mitigation relies on long-term planting rather than inherent suitability.

3. Severe and Persistent Odour and Air Quality Impact – Fundamentally Flawed Assessment (Policy OS2, EH6 and NPPF)

The proposed site at Deanery Farm is located to the north of Bampton, with the village forming a substantial residential receptor area to the south. The surrounding landscape is flat and open, providing no meaningful topographical screening to limit the movement and dispersion of airborne emissions.

Meteorological data from the local area, including RAF Brize Norton, demonstrates that:

• Winds are predominantly from the south-west and west
• These conditions occur for a significant proportion of the year
• Wind direction is variable and includes periods where airflow travels from the site toward Bampton

The northern edge of the village is most immediately affected, with specific receptors identified within the applicant’s own odour modelling. Notably:

• Residential properties in this area, including the author’s location
• Bampton Primary School, identified as Receptors 7 and 8 in the odour modelling

These receptors lie approximately 1 km from the site and represent highly sensitive locations, particularly given the presence of school-age children and nursery pupils.

With any change in wind direction—which is an entirely normal and frequent occurrence—odour and emissions have the potential to affect the entirety of the village, reflecting real-world experience of how odour disperses under variable meteorological conditions.

The application’s ammonia emissions modelling further reinforces concern. While dispersion is dependent on wind direction, even the applicant’s own diagrams indicate that Bampton is subject to increased exposure under prevailing conditions. However, the presentation of this data is misleading in that:

• The modelling diagrams truncate the extent of the village
• They fail to fully show the spread of the 0.02–0.05 ammonia plume, which would extend across a wider residential area

This omission understates the true extent of potential exposure and fails to provide a transparent or complete assessment of impact.

In addition to odour nuisance, there are serious air quality and public health implications. Ammonia emissions from intensive agricultural operations such as this are known to react with atmospheric pollutants including sulphur dioxide and nitrogen oxides to form secondary particulate matter (PM10 and PM2.5).

These fine particulates:

• Can travel significant distances beyond the source
•  Are recognised as harmful to human heal
• Are associated with heart disease, stroke, respiratory illness, and lung cancer

Government guidance recognises that children and the elderly are particularly vulnerable to these effects.

Despite this, the application places emphasis on the absence of impact on designated ecological sites (e.g. Sites of Special Scientific Interest at distances of approximately 2 km), while failing to adequately consider the direct and more immediate health impacts on the local population, including:

• The residents of Bampton
• The approximately 200 pupils and nursery children at Bampton Primary School, located significantly closer to the site.

The proximity of a primary school accommodating approximately 200 children represents a particularly sensitive receptor, and the potential for repeated exposure to odour and air pollutants in this context carries significant weight in the planning balance.

This represents a clear imbalance in the assessment, prioritising distant ecological receptors over proximate human health impacts.

The NPPF requires that development avoids significant adverse impacts on health and quality of life arising from pollution, including odour and air quality, and ensures compatibility between new and existing uses. Guidance from DEFRA and the Environment Agency further requires that emissions are effectively controlled and do not result in persistent community exposure.

The application fails to demonstrate that these risks—both in terms of odour nuisance and air quality—can be adequately mitigated.

The submitted odour and air quality assessments are materially flawed in that they:

• Rely on simplified modelling assumptions and limited receptor coverage
• Fail to adequately assess variable and real-world wind conditions
• Under-represent the spatial extent of emissions through incomplete mapping
• Do not fully assess peak emission events (e.g. clean-out, manure handling)
•  Do not properly evaluate cumulative or secondary pollutant formation

While variability in emissions is acknowledged, the assessments do not meaningfully evaluate the frequency, duration, or health implications of exposure for nearby residents.

Accordingly, the proposal gives rise to a clear and evidence-based risk of recurring odour nuisance and unacceptable air quality impacts on a large residential population, including vulnerable groups, and is therefore contrary to Policy OS2, Policy EH6, and the National Planning Policy Framework.

National evidence supports these concerns. Communities Against Factory Farming (CAFF) has consistently identified odour, ammonia emissions, and air quality impacts as key failings in the assessment of intensive poultry units across England. In multiple cases, CAFF has demonstrated that such impacts are underestimated due to reliance on simplified modelling assumptions and limited receptor coverage. This reinforces the concern that the current application does not adequately assess real-world exposure or the extent of impact on nearby communities.

4. Environmental risks (Policy EH6 & NPPF Chapter 15)

The proposal raises concerns regarding pollution from manure handling, waste, and surface water runoff, with potential impacts on water quality and soil. In addition, ammonia emissions may adversely affect sensitive habitats. The application does not provide sufficient assurance that these risks can be fully mitigated.

CAFF has also highlighted systemic failures in the assessment of manure management and nutrient pollution arising from intensive poultry developments. In catchments such as the River Wye and Severn, the cumulative expansion of poultry units has been linked to significant phosphate pollution and ecological degradation. This demonstrates the importance of robust and precautionary assessment, which is not evident in the current application.

5. Biodiversity impacts (Policy EH3)

The scale and nature of the development are likely to result in habitat loss and ecological disturbance. Any proposed mitigation or biodiversity net gain measures are unlikely to offset these impacts in the short to medium term.

6. Noise Impact – Limited and Assumption-Based (Policy OS2)

Noise from ventilation systems, machinery, and increased vehicle movements will introduce a level of disturbance that is inconsistent with the current quiet, rural environment.

The noise assessment:

• Uses only two receptors
•  Assumes reduced night-time operation
• Applies favourable shieldinDoes not fully assess night-time activity

In the absence of robust evidence, it cannot be concluded that the development would not result in unacceptable harm to residential amenity.

7. Transport Impacts – Misleading and Understated (Policy T4)

The development will increase heavy goods vehicle movements along rural roads that are not designed to accommodate such traffic. This raises concerns regarding highway safety, congestion, and impacts on residential amenity.

The Transport Statement:

• Uses averaged figures masking peak activit
• Does not assess peak traffic or safety 
• Excludes staff traffic

In the absence of comprehensive and representative assessment, it cannot be concluded that the impact on residential amenity would be acceptable. The Local Planning Authority cannot be satisfied that the development would not have a severe impact on highway safety. Where uncertainty exists, a precautionary approach should be applied. 

8. Drainage and Pollution Risk – Unsupported Strategy (Policy EH6)

The submitted drainage strategy is incomplete and unreliable and does not provide a sound basis for decision-making.

• No mains connection justification
• No percolation or groundwater testing
• Infiltration ineffective
• Discharge proposed without evidence

The submitted strategy is fundamentally unsupported and fails to demonstrate that pollution risks can be adequately controlled.

9. Air Quality and Ammonia – Cumulative Harm (Policy EH3, EH6)

• Generic emission factors used
• Background levels already exceede
• Cumulative impact not properly assessed

CAFF and wider UK evidence identify intensive poultry farming as a major contributor to ammonia emissions, accounting for a substantial proportion of national totals. These emissions contribute to the formation of secondary particulate matter (PM2.5), with well-established links to adverse health outcomes. CAFF has repeatedly raised concerns that these impacts are not adequately assessed at the planning stage, particularly in relation to nearby residential populations.

10. Ecology and Biodiversity – Inadequate Evidence (Policy EH3)

• Survey undertaken in November
• Drafting errors present
• Ecological connectivity understated BNG:
• Based on low baseline
• Relies on future management
• Lacks contingency

11. Heritage and Archaeology

• Archaeological potential unresolved
• Further investigation required

12. Quality and Reliability of Submission

• Drafting errors
• Missing technical evidence
• Heavy reliance on assumptions

13. Unsustainable Development and Cumulative Impact (NPPF)

CAFF has further highlighted that intensive poultry developments frequently deliver limited local economic benefit relative to their environmental and social impacts, often generating minimal employment while imposing significant externalised costs on surrounding communities. This imbalance is relevant to the assessment of sustainability under the NPPF.

14. Unsustainable development 

(NPPF)

The proposal fails to achieve a balanced outcome across environmental, social, and economic objectives. The environmental and amenity harms identified significantly and demonstrably outweigh any potential benefits.

The proposal fails to achieve a balanced outcome across:

•  Environmental
• Social
• Economic objectives

Approval would

•  Introduce industrial development into countryside
• Set precedent for similar schemes
• Cause cumulative degradation

15. Precedent and cumulative impact

Approval of this application would set a concerning precedent for further intensive agricultural development in the area, leading to cumulative harm to the countryside and undermining the strategic aims of the Local Plan.

CAFF has documented the cumulative expansion of poultry units in several rural areas, where multiple individual approvals have resulted in the incremental industrialisation of the countryside. This “creeping” cumulative impact is often not properly assessed within individual applications, despite being material to planning decisions.

16. Concern Regarding Potential Future Change of Use – Conflict with WODC Policy and Appeal Precedent

A key concern in relation to this application is that, once constructed and brought into lawful agricultural use, the proposed development could facilitate a subsequent change of use to non-agricultural purposes—most notably storage and distribution (Use Class B8) or other commercial activities—either through permitted development rights or future planning applications supported by fallback positions.

This is not a hypothetical risk but a well-established pattern nationally, and one that has been recognised in planning decisions and appeal judgments.

Modern poultry buildings are, by design, large-span, serviceable structures with access suitable for HGV movements. These characteristics closely align with the functional requirements of storage and distribution uses. Once established, such buildings frequently become candidates for conversion under Class R permitted development rights, or through applications where fallback positions are afforded material weight.

This pattern has been evidenced in multiple locations across England, including:

• Mulberry Bush Farm, Sarratt (Hertfordshire), where poultry/agricultural buildings were later proposed for flexible commercial uses including storage and distribution (B8)
• Chelmsford (Essex), where poultry houses were converted to B8 storage use following agricultural operation
• Rosamondford Farm near Exeter (Devon), where a poultry unit was later proposed for subdivision into B8 units
• Stratford-upon-Avon (Warwickshire), where land associated with a poultry farm was approved as a storage container yard;
• Wider rural areas such as Herefordshire, where poultry developments have formed part of broader diversification into commercial uses.

Importantly, planning appeal decisions have consistently recognised that such fallback positions are material. Inspectors have accepted that where a building could reasonably be converted to B8 use under permitted development rights, this possibility can carry significant weight in decision-making. In Oxfordshire and comparable rural authorities, appeal decisions have emphasised that the realistic future use of a building—not simply its stated initial use—must be considered when assessing overall planning harm.

In particular, Inspectors have noted that:

• The existence of permitted development rights can create a credible fallback scenario
• The potential for more intensive or harmful uses is a legitimate material consideration
•  Decision-makers should consider whether a proposal effectively establishes a building whose future use could conflict with spatial or environmental policies.

In the context of West Oxfordshire, this raises clear concerns in relation to the Local Plan 2031:

• Policy OS2 (Locating Development in the Right Places):

The site is located within a rural area where development is expected to be limited and appropriate to its context. A future transition to B8 storage or distribution use would introduce a use that is inherently traffic-generating and more appropriately located within designated employment areas. This would conflict with the spatial strategy by effectively creating a dispersed logistics site in the open countryside.

• Policy OS4 (High Quality Design):

While the proposal may be framed as agricultural, the design and scale of the building must also be considered in terms of its adaptability. A building capable of accommodating industrial or logistics uses risks undermining the requirement to respond appropriately to local context and character over the long term.

• Policy EH1 (Landscape Character):

The site lies within open countryside [and, where applicable, within the setting of the Cotswolds Area of Outstanding Natural Beauty]. A shift to storage/distribution use would likely introduce intensified activity, external storage, lighting, signage, and frequent vehicle movements, resulting in urbanising effects that would harm the rural landscape character and tranquillity.

• Policy E3 (Rural Diversification):

While this policy supports appropriate diversification, it requires that proposals are proportionate, compatible with their location, and do not generate unacceptable impacts. A transition to B8 use—particularly at scale—would exceed what could reasonably be considered proportionate or appropriate in this rural context.

• Policy T4 (Highway Improvement Schemes):

The local highway network, including [insert relevant local roads—e.g., narrow rural lanes, routes through nearby villages], is not designed to accommodate sustained HGV traffic. A distribution use would materially increase vehicle movements, with implications for highway safety, residential amenity, and road condition.

In addition to policy conflict, there are clear site-specific concerns:

• The proximity of nearby settlements such as [insert village(s)] would expose residents to increased noise, traffic, and disturbance in the event of intensified use
• The character of the surrounding area is predominantly rural and tranquil, with limited existing commercial activity
• The road network is constrained, with limited passing places, poor alignment, and sensitivity to increased heavy vehicle use
•  The site’s location does not benefit from the infrastructure typically associated with appropriate logistics or employment sites.

Taken together, these factors demonstrate that the acceptability of the proposal cannot be assessed solely on the basis of its stated agricultural function. There is a credible and evidenced pathway by which the development could evolve into a materially different and more intensive use, with impacts that would conflict with the spatial strategy and environmental protections of the West Oxfordshire Local Plan.

Accordingly, the Local Planning Authority is respectfully requested to:

• Give significant weight to the realistic prospect of future change of use when determining this application
• Consider whether the proposal would effectively establish a building capable of functioning as a distribution or commercial unit in the future
•  Assess the long-term and cumulative impacts on landscape character, highway safety, and rural amenity
• Consider the removal of permitted development rights or the imposition of conditions to prevent inappropriate future changes of use.

In the absence of such safeguards, there remains a clear and evidenced risk that the development could evolve into a form of storage, distribution, or commercial use that would be inconsistent with the policies and objectives of the West Oxfordshire Local Plan 2031.