Rabbit breeding facility – letter of objection

This is our letter of objection to the proposed rabbit breeding facility. Although welfare is our concern, it is not a planning concern, so any objections should be based on the relevant planning policy.

The planning application can be accessed here.

Objection to planning application ref: H23-1295-16 – Proposed building for the breeding of pet rabbits on Land off Whale Drove, Whaplode Drove, PE12 0UB

I am writing to register an objection to the above planning application on behalf of the Rabbit Welfare Fund (RWF), who have several concerns relating to the development proposal. The following points of objection are raised in respect of the application to erect a building for the breeding of pet rabbits on land off Whale Drove.

The main areas of concern over the planning application have been broken down into material considerations, with an assessment of how each aspect fails to meet the relevant planning policy. The National Planning Policy Framework (NPPF) sets out three dimensions to sustainable development as economic, social and environmental. While the proposed scheme at Whale Drove could contribute towards the local economy, in respect of the social and environmental benefits the proposals are seriously flawed. The social and environmental aspects will be considered more fully in the following paragraphs. By failing to meet the social and environmental requirements of planning policy, the proposal cannot be considered sustainable and is not in compliance with the NPPF or Policy SG4 (Development in the Countryside) of the South Holland Local Plan 2006 and Policy 10 (Employment Development in the Countryside) from the emerging Local Plan.

The agent’s supporting Planning Statement claims that the proposed use is an agricultural use and therefore is compatible with a rural location. In fact, the rabbit breeding facility is not classified as an agricultural use if the rabbits are being bred for domestic pets. The use could only be classified as agricultural if the rabbits are being bred for their meat or fur. On the basis that the proposed pet breeding facility is not an agricultural use, nor a land-based rural business, the development does not need to be located in a countryside location. Policy 10 (Employment Development in the Countryside) of the emerging Local Plan does not make any provision for businesses that are not agricultural or land-based in rural, countryside locations. Accordingly the proposed development is incompatible with the countryside location and the proposed location is unsustainable and contrary to Policy 2 (Spatial Strategy) of the emerging Local Plan.

This type of business should not be located in the open countryside, which ordinarily its protected from development in order to preserve the countryside and the landscape character. As such the proposal is thought to be contrary to Policy 29 (Design of New Development) of the emerging Local Plan and would be incongruous in this countryside location. No evidence has been submitted to demonstrate that there are no suitable buildings or sites within a settlement available for the purpose identified.

Furthermore the proposal is not justified by a business plan. Both of these requirements are identified in Policy 10 (Employment in the Countryside of the emerging Local Plan, and hence the proposal fails to meet the policy criteria. As mentioned above, no business plan has been submitted with the proposals, and on the basis of the Inspector’s comments in the previous appeal decision for the site, there is doubt over whether the business can run profitably.

The RWF have serious concerns over the viability of the business, on the basis that pet ownership of rabbits has dropped from 1 million in 2014 in the UK to 0.8 million in 2016 in the UK (TNS). With the demand for rabbits in the UK falling, the long term viability of the business is put into further doubt. If the business is not sustainable in the longer term, then planning permission should not be granted, as the harm caused to the landscape character by the erection of a new building, completely unrelated to any other built form in the locality cannot be justified in any way, and again, would be contrary to Policy 10 of the emerging Local Plan.

Given that the location of the development is remote from all services and the site is not served by any sustainable methods of transport, the proposal will generate an increase in traffic accessing the site (which is in an unsustainable location) generated through workers accessing the site and customers coming to view and collect animals. This is contrary to paragraphs 30 and 37 of the NPPF. A commercial business such as this should not be located away from more built up and more accessible areas. Further concerns regarding the proposal relate to a security/crime risk at the site, due to no 24 hour on-site presence being available. This problem is exacerbated through the fact that the site is in such an isolated location.

Finally, the RWF are also concerned over the welfare of rabbits that would be bred at the proposed facility. Very limited detail is included within the planning application on the enclosures, and as a commercial breeder the applicant would need to meet relevant legislation in terms of providing the correct standard of breeding cages and also transportation of the animals. On the basis of the information submitted with this proposal it is not understood whether the relevant welfare standards can be met, which casts further doubt over the viability of the business, should the facility then be required on welfare grounds to breed rabbits at a lower intensity.

I trust that the local planning authority will give due weight to the points of objection identified in this letter and resolve to refuse this planning application accordingly.