Sunday, August 16, 2020

Planning Objections using Sustainable Development Goals

Dear Offaly Planning Office, 

I have been teaching the 17 Sustainable Development Goals for 8 years, as a way to guide thinking and decision-making, in relation to climate action Directives. I have applied them to the application to use 50 acres of land to build a slaughter house and processing plant by Banagher Chilling Limited and find definitively that it goes against every one of the EU’s 17 Sustainability Goals, as follows. It also goes against every aspect of the Programme for Government for planning, as follows. It goes against public will, as you have seen by other objections. It will not even achieve the one thing it is suggested that it might: ‘A new player’ to help level the beef producing playing field in Ireland; China is not a new player, this plan has been hatched with Larry Goodman, Quealy’s and Simon Coveney no doubt as ambassadors and trade negotiators. Also, this is an extension to an existing factory so they are already partnering with our meat industry, especially with an investment that big. 

A manufacturing plant for Asia will take none of the small farmers' sucklers because the dairy 'waste' calves (decide if you agree with that concept too) will be too cheap to refuse. The Irish meat bosses will still not pay for higher welfare/quality animals – what the small farmers produce and please confirm if there is anything in this application that commits Banagher Chilling to paying a higher rate and for a particular quality or weight. Chinese agriculture standards are not known to be higher than ours. It is generally thought that the Covid 19 started in a Chinese Wet Market. That is an open-air slaughter house and representative of the food safety standards that they will replicate here. There will be no benefit to your county’s employment, your farmers’ industry, your constituents’ health or your reputation as the 2ndtier of government, as we face into the most important decade of climate action we have. We have no reason to believe that their agency staff will be treated differently to ours in terms of exposure to abuse and illness, even in regard to protections that are in place for the rest of Ireland’s workforce. 


Please visit, unannounced, the existing factory before making a decision. One friend, an engineer, was seconded to a factory to mend a machine on the line. He was horrified by the blood bath that he faced. The staff had reached a level of complete indifference to the animals or themselves. Absolute filth and entrails covered faces and clothes, no longer even wiped off and the processing of animals starting before they lost consciousness. Therefore, I  encourage every person in a decision-making capacity to visit a slaughterhouse and only then decide if they are comfortable being complicit in a development like this; on grounds of the social, work, accommodation and natural environment crises; the inability to protect all 140 bullocks from witnessing the slaughter of the other ones, every day; the pay and PPE conditions for existing workers, the water footprint of the animals and facility, the carbon emissions from the processing and animals and the revised industrial land use. Invite other possibilities for that large tract of land that could do a lot of good, if used properly.


Please see this as your first chance to really weigh up environmental, social and financial indicators and impacts and use the backing of EU commitments and the programme for government to say no to damaging developments. 



I propose that the Sustainable Development Goals outline a simple and crucial way to reach good planning decisions.  I have answered in terms of the Main Goals 7 & 13, then the Goals that directly contribute to the main goals and then those that indirectly contribute to the main goals.


Main Goals:

7. Sustainable and Clean Energy: 

Does the planning application suggest that the developers intend to use renewable energy sources? Are there any commitments to SSE Airtricity – fully renewable electricity or independent, renewable energy such as solar panels or wind turbines on the large site? Or a bio-digester. The latter would be feasible if the cow dung, as they crap themselves, in the face of death (as anyone would) was harvested and used to generate energy.


 13. Climate Action:

There is no shortage of studies showing that beef production is the most resource-intensive kind of meat production. A 2014 study from Proceedings of the National Academy of Sciences, for instance, revealed that producing beef requires 28 times more land and 11 times more irrigation water to produce than the average of pork, poultry or other types of livestock.


Beef also comes with a major climate impact. Beef production releases five times more greenhouse gases than the average of other livestock categories. It also produces six times more reactive nitrogen, which is known to cause air and water pollution. And compared to foods like potatoes, wheat, and rice, beef production requires a whopping 160 times more land and produces 11 times more greenhouse gases Climate Impact of Beef.


Climate action commitments include a move away from animal agriculture towards diverse vegetable and grain crops and fruit orchards, when this expansion project is attached to contrary increases in the national herd. Climate action includes a push to organic practices and away from the chemical degradation of food, land and water. Does the application include reference to, or commitment to minimising, nitrates and other flavour enhancers, preservatives and pumping-up methods, in meat processing? Does the application involve a commitment to avoiding one-use plastics in packaging? What stages of the circular economy will be in place: 1) Ecodesign? 2) Production/Reprocessing- avoidance of waste? 3) Distribution - transport methods and footprint to Asia and contamination risk? 4) Consumption – will the factory planned encourage consumers to buy less but high welfare/ high quality beef - In line with a changing national diet to less meat. Repair/Reuse – This is an extension to an existing factory. Does the application describe how the old machinery will be re-purposed or disposed of? Will there be a discount or sweeteners to neighbours to help them tolerate the development? Any other environmentally sound practices included in the design?


Is the council somehow financially obliged to the company/developer and do you need help from Super Junior Minister, Pippa Hackett or Eamon Ryan on Climate, or perhaps Grace O’Sullivan MEP? Is there a way to leverage support for better regional decisions?


Direct Contribution:

6. Clean Water and Sanitation: 

Water footprint: 1kg of Beef requires 15,000 kg of water. 1litre of milk requires over a 1000litres of water. Please refuse permission on grounds of fresh water usage. How much water will they use per day to wash down the new expanded slaughter house and processing lines? Will there be any use of chemical cleaners? Is there a risk of sanitary conditions killing biodiversity in nearby ground water and streams? Where will their water come from? Is it a well? Is there an aquifer? How will it be managed? Is it a share well with the residential people’s home nextdoor?


9. Industry, Innovation and Infrastructure

Will they pay rates? Would they be tax exempt as a foreign investment? Animal agriculture is an industry that Ireland is committed to reducing. There is an agreement that blind growth  is unsustainable. This is part of a blind growth experiment, where dairy was increased to huge herds, with the inevitable necessity of producing an unwanted calf each year, to keep the mother producing milk for the industry.


An innovation would include things like using the manure from farm animals to build soil fertility. 


An innovation would be a slaughterhouse designed to facilitate Ireland’s reduced meat production and consumption; committed to only kill cattle at four, five, six, seven and 8 years old, to facilitate the stopping of breeding of more. As well, the storing and distribution of the last generation of cattle, for food, could be managed over ten years. They could repurpose the Chillers – cold stores of the existing operation, to hold the nation’s beef. That would genuinely raise the value of meat and consumers would be allowed a quota, for example monthly or at Christmas. 


Another innovation would be planting a mixture of hazel and cob trees on the 50 acres to yield a plant-based milk; a small, high value crop, a carbon absorbing woodland, a community amenity, any number of artisan local products from oils to desserts to protein-rich savoury meals. 


An innovation would be the same land-owner being supported in creating a biodynamic 50 acres, pooling all the expertise in regenerative, best practice farming production and creating a ‘smart’ social farm showcasing social housing to passive energy standards, sheltered growing spaces for growing, fibre-optic technology to protect human and wildlife from wireless technology. 


Draw down Green Deal money for all and any of these things, so everyone feels supported in doing something positive rather than selling their soul for some intensive slaughtering. No one really wants to do that, deep down, only the very top tier of businessmen, completely removed from the actual logistics of the operation, who are profiting.       


15. Life on Land

Notice and point out how symbolic it is that the factory and old people’s home are far away from other communities. These are both disconnections that need to be addressed to support life on land. The disconnection from food means that many people do not know where food comes from let alone what happens to young unwanted animals in intensive agriculture; calves, piglets, lambs, layers’ male chicks and ducks. 


Human life is affected by the genetically modified feeds, glyphosate-drenched grazing and grains that accumulate in animals and therefore the food chain, affecting human health. Does the planning application include a detailed list of additives that will be used in the processing of meat? Does that list include any of the list, shared by WHO as potentially carcinogenic? Was there a break down of how much of the carcass will go for human consumption and how and where the entrails will go for pet food processing. Peer reviewed reports show that 40% of all emissions come from the pet food industry and so regulation for that is going to be important too as it would increase, in line with the increased kill-rate. 

Calves reared for meat from the dairy industry are separated from their mothers before they get the cholostrum they need to build their immune systems so that multiple doses of anti-biotics are needed to manage pneumonia in their first months. In the planning application, are there any labelling or record of the amounts of pharmaceutical product traces, to be applied or kept, for the new factory? Could these be asked for? Should these be asked for? Do the managers show that they are conscious of minimizing antibiotics in the food chain, as they are rendering crucial antibiotics ineffective, through over use?


Other unsustainable, on-land issues include run-off, chemical and animal waste. The building application goes against the commitment to move away from concrete as a basic material. There are many better materials such as these. There is a new recycling plant ,Trifol, who make recycled plastic blocks, in Laois. But insist Trifol do not continue to put melted wax into the human food chain through fruit coatings. Tidy up the supply chain as you go and write stipulations into each permission (like the old requirement to put in a native hedge, but stricter).


What is the provision for the new meat factory workers going to be? Will they share appartments on site? Will they be all foreign nationals? Will they be paid the minimum wage? Will the factory provide accommodation and minibuses for agency workers off-site? Is there a risk of workers being obliged to work in sub-standard conditions for excessive hours, if the bosses plan to include board and lodgings for staff to their contracts. Will they have contracts?


Noise pollution: In order to kill and process a hundred and forty bulls every day, there is going to be constant balling. Is there sound proofing built into the design? Are there parameters for the hours the slaughter line can operate? Did the applicants consult the residents of the care home to listen to any anticipated concerns or to put their minds at rest that for example, the slaughter stops at 5pm for definite.  If not, why not?



17. Partnerships for the Goals.

Are there any obvious partnerships towards sustainability, within the application? Have the operators approached farmers and guaranteed a better price than the other few operators of the other many factories? I know that many Kilkenny farmers for example, will take their cattle to Donegal as they are more likely to get a fair price there than down the country. What agreements have been made? Has there been payments made or promised to the council indirectly for other work, or directly for the development? Will a local transport company get the contract to carry the beef to the airports? Or ports? Will there be any local distribution of meat? Would there be any partnership with local biodiversity groups or EPA in monitoring the site, through the build and on-going operations. If you give permission for a multi-million project, you will not be able to retract it, as the investment is too high. You can refuse it now on every ground and invite and incentivize better proposals.

Indirect contribution to the main goals: 

1.    No Poverty.

Every small farmer is living in poverty. The majority still owe for feed from last winter and some still from the previous winter. The week their EU payment comes in, it goes out to pay for agri-chemicals and veterinary jabs under the heading ‘health programmes’. None of it goes to the farmer to put back into the farm, for basic maintenance, let alone towards taking a risk on a greening experiment, like investing in a mixed meadow seed rather than a monocrop, rich rye – no use to biodiversity. Species rich farmland produces heavier, healthier livestock and produce more milk - Older farming generations describe them as ‘well ground’, ‘cae ysbyty’ (field hospital) in Wales, and ‘the shore land’ used to describe the partial fields beyond the grass leys along the coast in Scotland. Species-rich grasslands for unwell livestock could be explored and savings made on veterinary interventions. Information on plants for use as medicinal remedies include ethnoveterinary and traditional medicine and zoopharmacognosy, which is the study of self-treatment.


In the current factory culture, factories will not take a small herd when they are ready. They will often agree to take one animal at a time and are allowed to refuse and/or deduct value on grounds of the animal being too heavy. Rather than a greater income for a heavier animal as in the past, farmers are now actually penalized for bringing an animal that is heavier to process. In addition, a recent DAFM audit of factory weighing equipment suggested that over 80% of them were outside accuracy to the extent of being non-compliant. Therefore, the factories are fixing their machines to further devalue animals. There are also the legendary Friday meetings between the Irish meat bosses to set prices. Does the planning application outline how new operators are going to avoid collusion with these systems and the perpetuation of poverty for farmers. 


2.    Zero Hunger

This application has impacts on the food industry in Ireland and the food industry in Asia. Ireland is already in trouble with Europe for our ‘race to the bottom’ in terms of no animal welfare. Europe is already in trouble for it’s international trade in grain. In both cases, at the destination, the produce is flooding a market with cheap produce and undervaluing local or better-produced food and causing poverty. 

3.    Good Health and Well being

Health in terms of great physical health requires that we eat fresh, raw foods with an intact vitamin and mineral profile. The nutritional quality of food is lowered a bit by cooking but preserved by fermenting, dehydrating and cooking at low temperatures. Organic food may not look different or taste different or better. In fact it may look lack-lustre or even stunted or otherwise flawed but it is the key to health as it is the only food that has not been grown, using chemical fertilisers, pesticides, herbicides, fungicides or preserved with sulphites, nitrates and other e-numbers. These chemicals accumulate in the body: We cannot naturally eliminate them. We cannot actively detox from them. They disrupt our enzymes and other digestive processes and are linked to various serious illnesses. In a study of MEPs, 100% of them had Round Up in their urinary samples, suggesting four times the safe amount in their bodies. Only 2% of Irish farms run on organic principles, without the use of chemicals, therefore nearly every meat product that comes out of the new factory would come from an animal fed imported finishers and other feeds with un-regulated gmo, treated seeds and chemical fertilizers etc in them. There is a movement to make small farmers organic to meet the EU directive but leave the intensive producers and feedlot owners to continue without a limit on their herd numbers or limit to their chemical use.


Meat is also hard for the human body to digest. It might be traditional to eat lots of meat but animal proteins of any sort are the first thing a nutritionist would tell any patient to give up to allow their natural systems to recover. In China, it self, the government issued a directive in 2016 for consumers to cut their meat intake by 50%, on environmental grounds. This application to process beef for China goes directly against their efforts to reduce meat intake China and Asia's Beef Market



Recent months have shown, without doubt, that working in a meat factory is a degrading and dangerous occupation. No one is advocating for them. There is no regard for life. There is no PPE or other Health and Safety oversight. The environment is completely profit-driven, with employee retention, satisfaction, continue professional development, pay and accommodation not even being a factor in the business plan. Just because the planning application was probably in before the pandemic broke in Ireland, planning offices must incorporate the new ways of working and guidelines and not facilitate another major development.

There are several studies that connect working in slaughter houses with domestic abuse. There are several Irish factories where suicide is a recurring problem.   

4,Quality Education

There are Horticulture Fetac level 5 and Agriculture Fetac Level 5 with a major uptake in some counties of 500 new pig farm managers in training, while horticulture (fruit and vegetables, heritage seed and organic varieties seed saving, plant science, soil science are taught and sustainable designs  developed. In this beef processing plant, vets who have studied for upwards of seven years will be expected to oversee the slaughter and food scientists will spend their working life testing levels of salmonella, bochilism, ecoli and other microbial problems. The production line workers will be asked in stifling heat with extractor fans that may have to be reversed to stop the stench reaching the residential home, as happened in Quealy’s QK Meats. These workers will not be given opportunity to progress professionally, just fulfil their conveyor belt role with body parts, burgers or machinery maintenance or cleaning. It would provide the epitome of unmeaningful employment to educated and uneducated alike.     

4.    Gender Equality

It has come to light during the pandemic that there are a few women who work in meat processing plants and maybe some more again in quality control and testing. When considering this planning application, what is more important than equal employment opportunities is the whole supply chain. If local councils could take the lead in linking breeding and milking practices with exploitation, mothering and milk for the species’ own young, it would really help consumers turn away from meat and dairy. A planning refusal that stated that Offaly was not open to intensive farming operations or related services would help constituents differentiate between small farm produce as good and supermarket mass produced produce as not good. This is the sort of education that is mentioned in the programme for government, leading by example. Ie. The planning office can say this application has brought to light the many inconsistencies in our climate action and biodiversity loss response. We will have to refuse the application but also ensure that from now on, only organic milk, fairtrade coffee and free range organic beef and vegetables from local farms that are in transition – therefore not using agricultural fertilizers and chemical sprays but have not yet completed their 6 years for certification - are served in public buildings.


8.Decent work and economic growth

Many would argue that killing animals using the Halal method does not constitute decent work. Does the application state what killing method will be used? Halal is supposed to include two factors: a) the animal should be fully conscious when his/her throat is cut (no stunning or gassing prior to slaughter) b) the person who slits the throat should say ‘Allah’. You will understand that there will be a big uptake on the first part of this ‘sacred’ process as it saves money and time not to have to render animals unconscious before killing. The carbonated gas was also in short supply last year and probably has environmental implications. It is unlikely that the second part is adhered to at all. This Halal slaughter method is contrary to Irish Animal Welfare laws as it is extremely cruel and leads to chaos amongst animals partially bled out and some going in and being hung up for their throats to be cut and then others starting to be ‘processed’, made into cuts of meat, when the animal is still moving and hoping to live.


My anxiety that this will be an exclusively Halal operation is that only cows are mentioned. The Muslim market considers pigs dirty and so that could be why they are leaving them out. The planning office must have a commitment that animals will be stunned before slaughter or there will be both National and EU repercussions.   


Economic growth is not to be attached to animal agriculture as it is associated with having a negative impact with high nitrogen and phosphorous loading and emissions. Consider the climate instability already in Ireland. During the drought in 2018, there was also a storm and electricity supply was lost. This meant there were thousands of dairy cows contrived to produce 70litres a day each, when only 10 litres a day is normal. Think of the water they needed. Then think of the horrendous mastitis, pain and life-threatening situations for herds when automatic milking operations came to a standstill. 


The economic growth county councils need to be facilitating is a subsistence plus lifestyle, where each household has a manageable quota and competence in caring for land, vegetables, animals, other people and services related to those things. All planning permissions and spending should be connected to conservation. This is justified as 80% of all industries and economies, globally, depend on a natural source. Biodiversity is the foundation of all growth and sustainability. Protection of water, soil and biodiverse insects and plants, is the protection of the global economy. 


10, Reduced inequalities

This project would increase inequalities many times over as the meat industry will justify lower rates for carcasses, no further standards are being required. 


Old people (who are probably paying over €1000.00 a week for care and accommodation) will be subjected to the sounds of the death throes of over a hundred cattle a day, the grind of the machinery, the arrival and departure of lorries. Many of those elderly people know that the climate science is at the front of politics now. They will have tried to stop DDT and other chemical weapons that have since become metamorphosed into agricultural chemicals. If you give permission they will feel even more disempowered, knowing that a development so blatantly archaic and destructive has been allowed. It will prove to them that Ireland can’t look after the people, only the corporations. 


Do you expect pay inequalities to be addressed at all in this operation? We do know that there is an annexed community in China, working as slaves in industry. What integration does the planning application propose for staff and payment and holidays, sick pay and other statutory rights?


11. Sustainable cities and communities

Has the planning office communicated with the Elected Councillors on this? Talked to the Biodiversity officers? Looked at the EPA impact and considered the wider implications for the concerted effort towards joined up thinking and think global, act local – not in a trading way but in a way that acknowledges that China can’t produce its own cows as the air pollution is so bad, 

Digital connectivity, biodiversity, clean water, transport - regular


12, Responsible Consumption and Production. 

Having researched the Chinese and Asian meat industry further, you will notice that they talk of beef and veal in the same breath. Veal is not reared in Ireland, due to welfare issues with raising calves in isolation, in darkness and tied, in order to make their flesh white and non-muscled and sinewy. We do however live export calves as young as 31 days to the UK, France and Holland to raise for veal. You need to make sure that this project is not going to facilitate a new veal market in Ireland where farmers keep their originally discarded calves of dairy cows but in non-compliant environments to bring to this new Asian trade avenue.


14. Life below water

Animal agriculture run off is a killer in waterways, drifting along streams and coastlines, using up oxygen and suffocating and sickening a myriad of aquatic life. “Dead zones” are the unintended consequences of our agricultural system trying to generate as much profit out of the land as possible. An island producing beef for a country like China (that is 137 times its size) would surely count as a plan to 'generate as much profit out of the land as possible'. China, let alone the rest of Asia - the proposed market, has one billion more people than the United States who have 340 million and Ireland has four and three quarter million. Trading with a country like that should be seen as not in line National, EU or Chinese climate action Directives.

Dead zones describe areas where hypoxia is taking place – basically an area of water with decreased levels of oxygen. Dead zones fluctuate in size with the seasons and move with the tides, but their presence is essentially guaranteed in areas where excess nutrients from conventional agricultural operations enter waterways.

16. Peace justice and strong institutions.

 I'd like to say that I don't expect An Bord Pleanala or county council planning offices to work through decisions like this, goal by goal, priority weighting them and accordingly....but I do. If people don't know how to reason, prioritise or know enough about different sectors or financial, environmental or social impacts, then involve another department, phone a friend or phone me. I live and breath just and systematic reasoning. County councils can only be strong enough institutions to protect from corporations, if they require comprehensive planning applications, addressing each one of the sustainable development goals and if they don't, councils can invoke EU law and support via the above sort of considered and systematic reporting to accompany your letters refusing permission.  


Thank you, 

Best regards, Frances


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