05/10/2012
South Derbyshire District Council
Planning Services
Civic Offices
Civic Way
Swadlincote
Derbyshire
DE11 0AH
Dear Sir/Madam,
RE: Objection to Planning Application 92012/0812
Establishment of a rabbit breeding and rearing unit and wormery on agricultural land.
Background
I write on behalf of Compassion in World Farming (Compassion), the world’s leading farm animal
welfare charity, to register the organisation’s objection to this proposal.
Our opposition to the proposed plan falls into seven broad areas:
1. The retrograde step in farming practices that this proposal represents, including welfare
concerns.
2. The dependence of the proposed farming system on high levels of antibiotic treatment.
3. Potential public health issues as a result of the proposal.
4. The impact on the local wild rabbit population
5. The damage to the public image of Derbyshire and the resulting impact on local businesses
and residents
6. Insufficient access to the site and increased traffic
7. The lack of essential information within the submitted plans; specifically regarding the farming
system for fattening rabbits and the intended slaughter method.
However, before detailing these objections we wish to ensure that the Planning Services have a
sufficient understanding of the nature of intensive rabbit farming. Earlier this year Compassion
visited several rabbit farms in Europe, which – from the limited information available in the proposal
– operate systems similar to that which is intended in Castle Gresley. Film footage is available
here: http://www.youtube.com/watch?feature=player_embedded&v=wxsRYaeN9GE
1. The retrograde step in farming practices that this proposal represents, including
welfare concerns
The limited information available in the application suggests an intensive rabbit farming system,
with the rabbits being housed in suspended wire cages.i There is no mention of enrichment
materials for the rabbits. Therefore, the system appears to be a barren battery cage system.
The space and environment in which these rabbits will be kept can be likened to that experienced
by egg-laying hens in barren battery cages – a ban of which is now in force across Europe.
There are currently no commercial scale intensive rabbit farms in the UK. This application therefore
represents a new farming system for the UK. Introducing a new system based on the barren
battery cage model is a retrograde step and it seems inconceivable that it would be considered 13
years after legislation was introduced to outlaw the same system for laying hens.
Most commercially farmed rabbits in Europe are kept in barren wire cages where their natural
behaviour is severely restricted. The cages are usually in stacks in closed buildings as per this
application.
There are very serious welfare issues affecting rabbits in barren-cage farming systems. Rabbits
usually move by hopping, with each hop covering around 70 cm of ground, but during grazing they
move more slowly. They can run at speeds of up to 30 km/hour, jump higher than a metre and
make sudden changes of direction by zig-zagging. Rabbits have highly sensitive senses of smell
and hearing. They are very alert animals and regularly interrupt activities to check for danger by
sitting or rearing up on their hind legs with ears erect.
The application does not give information on the space allowance per rabbit. However, this is likely
to be much smaller than the area necessary to natural behaviors to be expressed. The floor space
and height in these systems is often so restricted that caged rabbits are frequently unable to move
normally and adopt normal postures such as lying stretched out, sitting and standing with their ears
erect, rearing up, turning around comfortably and hopping. The lack of opportunity for exercise in
caged rabbits can lead to weakened bones.
In a natural environment, rabbits dig a large and complex system of burrows which they use for
resting, hiding and rearing their young. They will usually feed at dusk and dawn and at various
points during the night.
Commercially farmed rabbits are generally fed on pellets and, except for a feeder and drinker, no
other structural objects are usually provided in the battery cage. The barren environment and lack
of forage feed (e.g. hay) can lead to rabbits developing stereotypical behaviours such as excessive
grooming and repetitive gnawing or nibbling at the cage. Females that are being reared for
breeding or are not nursing are often particularly badly affected as they are typically fed on a
restricted diet.
Rabbits are social animals, living in stable groups of usually between two and nine adult females,
one to three adult males and their offspring. Serious aggression is rare once a stable hierarchy has
been established and strong relationships develop between individuals, who will choose to remain
close to each other and rest together, often in body contact. Mutual grooming is an important
behaviour to reinforce social bonds.
Growers are often housed in pairs or groups, but breeding does and bucks are usually kept in
individual cages, denying them the opportunity for social interaction. Individually caged rabbits
show more stereotypical behaviour than rabbits housed in groups.
Typical intensive system cages are mainly constructed of wire and sometimes the sides are solid
metal sheets. Some farms use floor mats to cover part of the cage floor but usually the floor is
made entirely of bare wire. Breeding females and males kept for long periods on wire mesh floors
commonly develop sores on their footpads and hocks; these sores cause chronic poor welfare and
can be so severe that they are a common reason for culling. A survey of French rabbit farms found
that on average 12% of female rabbits had paw injuries that were sufficiently serious for them to
show obvious signs of discomfort; on some farms this level was as high as 40%.
The gestation period for rabbits is 31 days. Between 80% and 90% of commercial rabbit farms
inseminate does on a 42 day cycle, i.e. 11 days after giving birth. As a result female rabbits
effectively spend their whole lives lactating - they rest less than one week in sixii. Hormone
treatment is often used to synchronise the time of breeding and, on most commercial farms, does
are artificially inseminated. The hormone treatment can also increase litter size, which puts more
stress on the does, and can cause stillbirths.
An average doe gives birth to 60 kits each year, but losses are high: the typical loss of kits from
birth to sale on closed-cycle farms (i.e. farms which keep both breeding and growing rabbits like
the one in this application) is between 15 and 30%.
Breeding does enduring this type of reproductive cycle can suffer from loss of body condition and
metabolic disease. The average lifespan of a female in commercial units is five to six litters. The
restocking rate of rabbit does in farms is often 100-120%.
Breeding males have been selectively bred for increased growth rate, which can lead to chronic
lameness. The problems of fighting necessitate that bucks are kept in separate cages from
maturity at about 12 weeks of age.
Respiratory and enteric diseases can cause acute pain, whilst chronic conditions such as ulcerated
feet and hocks, mastitis, mange, ringworm and abscesses can cause prolonged suffering in farmed
rabbits.
Mortality of commercially farmed rabbits is very high, with typically 100% of breeding does dying or
being culled and replaced each year and losses of 15 to 30% of growers from birth to slaughter.
The main causes of mortality are enteric and respiratory diseases and the main reason for culling
is reproductive failure due to infertility or mastitis.
Therefore, it can be seen that caged rabbit farming, particularly in barren battery cages, is an
inhumane and outdated form of farming. Introducing it into the UK is an illogical and retrograde
step. We believe that granting permission for this development would not be consistent with the
UK’s requirement (under the Treaty on the Functioning of the European Union, commonly known
as the Lisbon Treaty, Article 13) to [in formulating and implementing the Union's
agriculture...policies,] “pay full regard to the welfare requirements of animals”. Not only should the
Lisbon Treaty be taken into account but also the UK’s Animal Welfare Act 2006 which requires that
an animal’s needs are taken to include “the need to be able to exhibit normal behaviour patterns.”
2. The dependence of the proposed farming system on high levels of antibiotic
treatment
Rabbit farming is dependent on very high use of antibiotics. In France in 2010, which is the 7th
largest producer in the world, rabbit farming used over 7 times more antibiotics per kilogram of
meat compared to poultry and over 5 times more than used in pig meat.
In a briefing written in April this year, the British Veterinary Association said: Antibiotic or
antimicrobial resistance is a significant global animal health and public health concern.
Antimicrobials are essential for the treatment and prevention of infectious and zoonotic (infectious
diseases that can pass from animals to man) diseases in both animals and humans. They are
fundamental to animal health and welfare, the safety of food products derived from animals, and
global food security. The antimicrobials used in veterinary and human medicine are closely related;
every use can increase the risk of development of resistance and there is potential for such
resistance to transfer from animals to humans.iii
Introducing a new farming system to the UK, which relies so heavily on antibiotic use, would be
irresponsible in the face of an antibiotic resistance situation so acute that the Director-General of
the World Health Organization, Dr Margaret Chan, warned on World Health Day 2011 of “a postantibiotic era, in which many common infections will no longer have a cure and once again, kill
unabated.”
3. Potential public health issues as a result of the proposal
The introduction of any farming system dealing with waste and feed increases the potential risk of
rat infestation. This type of farming requires the feeding of concentrate feed, as the animals are not
able to graze. The application states an ambition for 800 breeding doesiv, each producing 52
kittens per year, resulting in more than 42,000 rabbits on site per year (kittens plus does). This
number of rabbits will require a large volume of concentrated feed. The proliferation of rats can
pose a risk to human health, including the transmission of Weil’s disease (leptospirosis) to local
water courses.
The contribution of this type of farming to the growing antibiotic resistance problem, as detailed
above, should also be taken into account.
4. The impact on the local wild rabbit population
The application states that ‘Control of wild rabbits on site may be required to reduce the risk of
transferrable diseases (e.g. myxomatosis)’v There is no detail about how this control will be
undertaken, but the implication is that the local wild rabbit population would be culled.
As well as raising concerns about skill and licensing for such activity (there is no mention of
professional fees in the budget – schedule 1), there is a significant risk that this culling will be
ineffective. Taking pot shots at local wildlife cannot be said to be an effective disease control
policy. The haphazard culling of wild rabbits may also have significant impact on local ecosystems.
British wildlife deserves to be respected and protected.
5. The damage to the public image of Derbyshire and the resulting impact on local
businesses and residents
This proposal has attracted attention, both locally and nationally. The start up of a new farming
system, with such poor welfare potential will attract significant protest and media interest. This may
be reflected in physical protests which may require police presence, at a cost to the tax payer.
In addition the reputation of Derbyshire will be sullied by association with this outdated and
inhumane system. A comparison may be drawn with the port towns through which live animals are
or were exported.
Damage to the reputation of Derbyshire may have a significant impact on local tourism businesses.
Local residents are making their feelings clear. Several social media groups have been set up and
a poster campaign is underway. Planning Services have a duty to respond to public opinion.
6. Insufficient access to the site and increased traffic
This application will result in increased site trafficvi. The site does not have access that is fit for
purpose for the farming operation. The access road crosses a wooden bridge with a 3 ton weight
limit therefore few lorries can cross it. The other access referred to appears to be a bridleway,
making its use for heavy vehicles very questionablevii. This track is used by people, including
children, to access a local nature reserve.
Clearly this application is not able to demonstrate suitable access for the vehicles that will be
essential to the proposed farm.
7. The lack of essential information within the submitted plans; specifically regarding
the farming system for fattening rabbits and the intended slaughter method
The application as submitted is not fit for purpose. A very significant amount of vital information is
missing. Without this information our opinion is that it is not feasible to even consider this
application.
In particular the application contains very little detail on the farming system that is proposed. There
is no detail of cage dimension, scant detail on materials etc. Therefore it is not possible to judge to
what extent the welfare requirements of the animals will be met, if at all, or to make an
environmental impact assessment. There is no information at all regarding the housing system for
the fattening rabbits (growers), given that this group will represent the vast majority of animals on
site this oversight makes the application significantly incomplete.
There is also no detail on a proposed slaughter method. It is not clear that this has even been
considered. Either the rabbits will have to be slaughtered on site - in which case facilities for
humane slaughter in compliance with all relevant legislation would be required along with skilled
staff - or the animals will be going off site for slaughter in which case the details of the proposed
slaughter house, the number of vehicle movements and the impact on local communities of lorryloads of live rabbits going for slaughter must be given.
In conclusion
This application has implications for the future direction of farming in the UK. In making your
deliberations we urge you to consider the points we raise in relation to UK farming, welfare, public
health, the impact on Derbyshire and access to the site. In particular we ask you to consider
whether the information contained in the application is complete.
I would be grateful for your consideration of our submission and hope you will feel free to contact
me if I can help further.
Yours faithfully
Dil Peeling
Director of Public Affairs
T. +44 1483 521 908
E. dil.peeling@ciwf.org
i
Agricultural report, sec 6.4, pg 9
European Food Safety Authority, The impact of the current housing and husbandry systems on the health
and welfare of farmed domestic rabbits, 2005 pp 32-33
iii http://www.bva.co.uk/public/documents/Briefing_MEPs_Medicines_Apr2012.pdf
iv Agricultural report, section 5.1, pg 7
v Agricultural report, section 5.4, pg 7
vi Agricultural Report, section 10.3, pg 13
vii Agricultural Report, section 4.8, pg 6
ii