Representation by AB Agri Limited (AB Agri Limited )
- Date submitted
- 15 September 2022
- Submitted by
- Members of the public/businesses
AB Agri Limited owns and operates ABN in Flixborough Industrial Estate. ABN is a leading British manufacturer of animal compound feed for the commercial pig and poultry industry in Great Britain. The manufacturing of specialist breeder feed at the plant in Flixborough is carried out in a biosecure plant to meet UK and other regulatory standards. The animal feed production at Flixborough produces 0.4million tonns of animal feed per annum and is of national importance to the UK food security and its failure will have a serious impact on the supply chain, leading to a shortage of meat available to the general population. AB Agri engaged in the public consultation undertaken by the Applicant in June – July 2021, through a submission of a letter and a subsequent workshop held by the Applicant in December 2021. This was followed by written correspondence between the Applicant and AB Agri, including letters from the Applicant and AB Agri in February and April 2022, respectively. Part of the AB Agri site is included within the DCO limits, proposed for temporary possession (plot no 5-54). Notwithstanding that AB Agri’s agent sought to engage with the Applicant’s agent on this matter, there has been no meaningful engagement from the Applicant. We also raised serious concerns about a prejudicial impact on the existing operation arising from increased risks to biosecurity and flood risk during the pre-application stage. However, the Applicant’s response and the DCO application have not satisfactorily addressed our concerns. Therefore, we object to the proposed development on specific grounds as outlined below: Biosecurity: The raw materials intake of ABN plant is located in close proximity to the proposed ERF and the RDF delivery route. Risks to the biosecurity of the ABN’s plant, particularly potential salmonella contamination from waste handling, are of significant concern. The Applicant’s response to AB Agri’s concern is stated in ‘Regard had to consultation responses’ document (ref: 7.2.18) but the details set out in the Application do not provide adequate mitigations, as it confirms that not all RDF materials will be delivered in sealed containers, and materials to be delivered by HGV will be in bales on curtain sided trucks/tippers (which goes against assurances made in their pre-application correspondence). We note that the delivery routes to the ERF are on the southern face of the building, away from AB Agri, but it does not preclude HGVs passing AB Agri on First Avenue with RDF materials in bales and/or uncleaned vehicles. The Applicant states that they are continuing to engage with AB Agri to resolve all outstanding technical issues, but there has been no engagement from the Applicant since February 2022. We consider that the following mitigation measures are necessary: - A condition requiring RDF to exclude no material of animal origin; - A condition requiring all RDF to be delivered in sealed containers and wrapped/sealed bales; - A condition requiring an Operational Environmental Management Plan to include wheel washing and disinfectant regime for RDF delivery vehicles, and - A routing agreement that HGVs do not drive past ABN. If these measures are not applied, then AB Agri’s operations will be substantially prejudiced and a knock on effect on the supply chain as described above will arise, unless wide ranging and costly measures are applied on site to mitigate the biosecurity risk that would rise otherwise. Flood Risk: We note that the flood model used to inform the Flood Risk Assessment is coarse and is only able to predict flooding to an accuracy of ±25mm. In addition, the model does not appear to be representing a potential key flood route (overtopping of the wharf). Therefore, as we raised at the pre-application stage, we do not consider that the model is appropriate for a detailed assessment of flood risk, which gives rise to a concern whether the proposed flood defence options are adequate to ensure development does not result in an increased flood risk to the AB Agri site. Temporary Acquisition: ABN’s operation at Flixborough is a nationally critical animal feed mill site. As such, AB Agri cannot agree to any of the site being released on a temporary basis, as operationally ABN requires full access around all buildings and temporary land take would be a disturbance to the business. There are also inconsistencies in the DCO application, in that it is identified as needed for temporary construction purposes (including potential works, signage and utilities) in Schedule 12 of the draft DCO and for the construction of a flood defence in the document ref: 7.2.18 and the Environmental Statement. We request the applicant’s clarification on the matter. Fundamentally, the Applicant has not engaged with AB Agri’s agent (JLL) on this issue to date and therefore AB Agri does not have the necessary information to ascertain the impact on the business from the proposed temporary acquisition. In this context, AB Agri has no choice but to reserve its position until further information is made available. Access: It is requested that the phasing of the construction works ensures that access to ABN for all vehicles is maintained for the duration of the works. We therefore wish to reserve our right to submit a full representation on the basis of the above during the Examination process.