Avara/Cargill have a cunning plan...
I had been trying to reach one of the county’s planning officers by telephone, hoping talk would be better than emails, until getting no answer I finally sent an email to this person. The automatic response they sent was that they were unavailable because they were writing a report. I believe, and hope, that this will be the report of their life, because it seems likely that this officer is caught between a hugely powerful company on the one hand, and a planning system that may be more at home deciding if you can build an extension than with making decisions about a complex project that may – should - or very well may not – offer solutions that are urgently needed for the sake of the ecological viability and biodiversity of the Wye Valley, a huge and crucial part of the UK as well the farming community. So actually everyone. No pressure.
This would almost certainly not have been happening were it not for the energy and dedication of hundreds of local environmentalists, an extraordinarily impressive example of citizen science and environmental activism forcing a giant corporation to take action, or to pretend to take action, to address the ecological damage it has been causing for many years. This may be real, or it may be cynical opportunism on the part of the company. Some cynicism on our part, in the circumstances, is inevitable.
The company with the greatest responsibility for the pollution of the whole River Wye catchment is Avara, which is part of the Cargill group. This American company believes, like all similar (dare I say capitalist?) corporations, that its main responsibility, possibly its only responsibility, is to its shareholders. In the case of Cargill this is approximately 18 family members of this privately owned company, all exceptionally rich people, many of them billionaires, among the richest people in the USA or indeed the world. Avara was formed by Faccenda Foods and Cargill to run what had been the old Sun Valley Poultry business based in Hereford. Faccenda are apparently also a private company, as far as I can see, with a bit of a spotty record regarding environmental issues, but nothing to touch that of Cargill, their puppet master. “In my 40-year long career in Congress, I took on a range of companies that engaged in abusive practices,” former congressman and Mighty Earth Chairman Henry Waxman writes in the {Mighty Earth report 2019}. “I have seen first-hand the harmful impact of businesses that do not bring their ethics with them to work. But Cargill stands out.” “As one of the largest companies in the world, Cargill has a responsibility to address its outsized impact,” Mighty Earth CEO Glenn Hurowitz said. “Mighty Earth runs campaigns around the globe to advocate for sustainable business practices, and Cargill kept showing up when our investigations identified bad actors. Whether we were working on palm oil in Southeast Asia, cocoa farming in West Africa, or soy cultivation in South America, Cargill was always there, ready to thwart progress and impede joint conservation efforts”.
Because of the work of a growing number of energetic and able pressure groups, environmentalists, citizen scientists, film makers and journalists, keeping the idea of the dying River Wye before the public, Cargill/Avara has responded to the activism and outrage over the condition of the River Wye by announcing they will address the problem of manure polluting the river system.
The practice of Cargill, according to the US environmental pressure group Mighty Earth, has been, if cornered, to agree to make adjustments to placate environmentalists but then to not abide by these commitments, which is one of the many reasons why Mighty Earth gave them the title of ‘the worst company in the world’.
Cargill/Avara have taken two steps to either clean up their act or their image. They have published their Sustainable Poultry Roadmap… https://www.avarafoods.co.uk/getmedia/89cfe5aa-8893-4c98-ac8b-d59b8da90f43/Avara-Poultry-Manure-Roadmap.pdf which starts by implying the problem is only phosphate pollution, the most obvious cause of the algal blooms smothering the River Wye. (In fact poultry units cause pollution also because the manure contains nitrates as well as phosphates, and they also produce methane and ammonia, greenhouse gases that very measurably pollute the air of Mid Wales and damage fragile upland ecosystems). The Roadmap document has a nice homey honeycomb graphic aiming to show that lots of other people are polluting the Wye. It describes plans to reduce phosphates in feed and to implement soil management standards, whatever that means, and to move some manure out of the catchment where, presumably, it will pollute other rivers. The most significant announcement is their plan to have a ‘novel’ Anaerobic Digester (AD) on stream by the end of 2024, which, although the Roadmap does not say so, is planned to be erected in the grounds of Whitwick Manor in the catchment of the River Frome near Ledbury.
For their Roadmap to have any impact on the Wye catchment the digester would have to remove the nitrates and phosphates from the manure. This is not something anaerobic digesters do. This anaerobic digester will produce a residue, digestate, that still contains all the nitrates and phosphates, which is why it can be touted as a manure. If the digester does not remove phosphates and nitrates then we are, as my father used to say, being sold a pup.
My first reaction was very cynical. It may be much easier to get planning permission for a giant AD gas plant plonked down in the middle of Herefordshire if it is positioned as a response to the problems of the River Wye. If you wanted to build such a huge plant in order to earn large amounts of money through the Renewable Heat Incentive (RHI) payments, then describing it as a solution to the problems of the River Wye is likely to exert powerful leverage on the planners, who might not wish to be seen as having turned down a scheme supposed to be able to save the Wye. (The RHI payments are funded by a levy on energy bills, principally electricity, amounting in 2021 to roughly £10 billion. I’m not suggesting we shouldn’t all pay the levy, merely that we possibly shouldn’t pay it to Cargill/Avara).
My second reaction was to wonder how this AD plant would remove harmful phosphates and nitrates. Ordinarily AD plants produce methane, temporarily containing the emission of the greenhouse gases (GHG) Methane and Carbon Dioxide from manure, but then releasing all the Carbon Dioxide when the gases are used and the Methane (CH4) is burnt. The product of burning methane is CO2 and H2O. The digestate left at the end of the digestion process still contains the nitrates and phosphates, which is why digestate is used as farm manure. (Nitrates and phosphates are used loosely here for all forms of nitrogen and phosphorous).
The Road Map gives very little information about this. It mentions plans to support ‘alternative, sustainable homes for poultry manure’, which almost certainly simply means trucking it to some other river catchment, and it also says the AD plant coming on stream in late 2024 will be ‘novel’. The question that is not answered in the Road Map is whether the novelty will include stripping out nitrates and phosphates from the digestate. Such technology exists, but we need to know if it can be done on the scale required, if indeed they plan to do it, and also what chemical impact results from such processes. That they call it a ‘novel’ process suggests they intend to use an untried system that may not work.
The only other source of information available to the public is contained in the planning application for an AD plant at Whitwick Manor that will process 100,000 tons of poultry manure annually, about two thirds of the amount Avara claim to produce. It is important to note that it is very difficult to search through all the planning documents to find information, which makes scrutiny of such plans by the concerned citizen very difficult.
The plan appears to be to pass the liquid fraction of the digestate, which contains most of the nitrates and phosphates, through tanks containing a specially prepared clay substance, where phosphates will be deposited by adsorption. The liquid will then be passed through reed beds. The plan appears to be for the clay and probably the substrates of the reed beds to be cleared out as necessary and spread on farmland somewhere.
The first problem here is that the nutrients are not removed by this system (eg for use as general chemical feedstocks) but spread back on the land, where they will either contaminate the Wye or another catchment.
The second problem is that the process may well not work. That the process is described as ‘novel’ by Avara and as ‘conceptual’ by its designers in their document included in the planning application does not inspire confidence. Put crudely, this seems to imply that they are not sure if it will work. And there seems to be no plan to remove nitrates, except possibly, and here I really am being cynical, because ammonia -a powerful greenhouse gas - will almost inevitably escape, and being a nitrogen compound this may reduce the nitrogen levels in the digestate.
There appear to be more sophisticated, tried and tested processes available, such as those used in the Netherlands to address over-nutrification caused by their pig industry. Avara/Cargill could obviously afford whatever such plant costs, if they genuinely cared enough about the problem and wished to work towards a more acceptable and sustainable chicken industry, but the planning application does not appear to include such plant. And for some reason the plant is being built on land belonging not to Avara but to the local biogas baron. This hands-off approach may explain their unwillingness to invest in the necessary technology. Or they may simply be trying, as usual, to send as much money as possible to their super-rich owners.
This plan appears to me designed to pay lip service to cleaning up the Wye and actually to combine business as usual with developing a new income stream from biogas production. This gas plan is more likely to be accepted because it may be using environmental concern about the Wye Valley to leverage planning permission for an otherwise questionable development. The lever should not be allowed to work if the process may not work.
The scheme also fails to address the global problems of the chicken industry. For a major source of the pollution problems of the Wye is the business model which supports chicken enterprises that are completely unsustainable, because they depend on importing feed from areas such as the Brazilian Cerrado region, where pristine nature has been turned, largely by and for Cargill, into soya monocultures. This is a major source of the chicken feed that produces the chicken manure that pollutes the Wye. Sustainable chicken production, using feed grown on the chicken farms, would recycle nutrients within each farm. It would no longer contribute to the clearing of the Cerrado or the pollution of the Wye. The clearance of the Cerrado for soya farming is responsible for an estimated 250 million metric tons of carbon dioxide emissions each year, about the same as the annual emissions of 53 million cars, as well as risking the loss of unique creatures such as the Maned Wolf. Cargill is damaging much of the world beyond the Wye Valley.
Maybe Cargill realises that the mechanised chicken industry that they pioneered cannot in the future be part of a sustainable way of living on this planet. Maybe they are a sinking ship on which we are all going down. But in the maybe-hopelessly-optimistic meantime we need measures to contain the damage, measures that are far more serious than those that seem to be being proposed here. I hope the planner writing their report and the planning committee considering the application have the courage to recognise that this is a dud, and to send Avara back to come up with some technically adequate solutions. Otherwise we may have to wait too many years too late to find out that this digester cannot solve the problem. If the largest privately owned company in the world cannot adequately address this problem of their own making they should be sent packing.
I have now written to that planning officer to make the following representation, which I suggest might be a guide to any readers wishing to contribute to the campaign to clean up the River Wye. There is still time to make representations.
Representation in respect of planning application P222728/N for an anaerobic digester at Whitwick Manor.
I submit that the planning process needs to take into account the following issues, also taking into account that this application appears to be closely connected to Avara's chicken manure Roadmap. Otherwise the chicken manure problem should not be allowed to influence the decision.
Digesters do not of themselves deal with or reduce the nitrates and phosphates (hereafter ref. to as nutrients) in chicken manure and are not in themselves any part of the solution. DIGESTERS DO NOTHING TO GET RID OF THE HARMFUL NUTRIENTS.
Bringing chicken manure to a central point with all the associated issues of noise, pollution etc etc might well be worthwhile if it made it more practicable to extract the nutrients.
Is the existing plan to remove phosphates using clay and reed beds proven technology, and if so why does the designer call it 'conceptual' and the Roadmap call it 'novel'?
Is the existing plan using clay and reed beds in any way adequate to the phosphate problem? Is there any evidence whatever that it will work?
Why does the existing plan not appear to contain any substantive measures to remove from the manure the nitrates, which are a very significant environmental problem?
Avara and the farmers are central to this problem and it is therefore worth questioning if a plan by an existing biogas entrepreneur to run a biogas plant is an appropriate response to the manure problem or is essentially an opportunistic private business venture. Therefore
What responsibilities and accountabilities will Avara have? Is this hands-off approach satisfactory or appropriate? Will it allow Avara to disclaim responsibility for things for which it should have a duty to be responsible?
There exists the technology to strip out the nutrients, and a company the size of Avara with the backing of Cargill beyond all doubt has the resources to build such a plant. So we need to ask why they are not suggesting this kind of investment.
Is the absence from this application of adequate technology connected to the fact that this is essentially a farm business and not an Avara project?
Allowing this digester will allow Avara to claim they are dealing with the problem. Refusing the application will allow the community to continue to apply pressure on Cargill/Avara to come up with an workable solution by investing in adequate proven technology.
With the greatest respect to the planning system, is there a case for escalating this to a serious planning or other enquiry involving all local stakeholders? If this scheme is inadequate, as I submit, then there will be little to be lost in delaying it while we investigate thoroughly. This citizen scientists and environmentalists who have been able to put pressure on Avara have much to contribute to a solution to this problem.
Yours respectfully etc.
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