Hydroponics, Aquaponics, Aeroponics and Aqua Farming Guidance Note
The purpose of this planning guidance note is to assist in the application of planning policies and the assessment of planning applications which relate to local food production, specifically developments involving hydroponic, aeroponic, aquaponic and aqua farming (HAQ).
This guidance note should be read by applicants prior to the submission of all relevant applications. Determining when planning permission will be required for HAQ installations will be dependent upon a range of factors including the scale and location of the proposed scheme. In all instances, advice from the Department of Planning should be sought before commencing development works.
In simple terms, hydroponics can be described as growing plants in the absence of soils. There are a number of different variations of hydroponic growing techniques. One of the most common is where the roots of a plant are placed in a water based, nutrient solution. The roots can be supported by a ‘growing medium’, such as rockwool, clay pellets or sand, however, the nutrition that the plants require to grow all comes from the nutrient solution and not the growing medium.
Some of the known benefits of hydroponic farming are:
Aquaponics is the process of combining aqua farming (see below) and hydroponics in a closed loop system, the end result of which is the growing of both fish and plants (e.g. lettuce, kale, watercress and herbs). Although fish is the most common type of aqua farming that takes place using this type of system, other aquatic animals can be used such as snails, crayfish and prawns. Whilst fish can be harvested from aquaponics systems, the most common type of system is primarily designed for growing plants.
In addition to the benefits associated with hydroponics, aquaponics has the following benefits:
There are also cons to operating both hydroponics and aquaponics systems such as the upfront and maintenance costs, regular supervision is required and waterborne diseases can occur.
Aeroponics is a method of growing plants by suspending roots in the air and irrigating them with a nutrient-dense mist. This type of system differs from aquaponics, where roots are normally submerged in a nutrient-rich solution. Aeroponics systems can be highly efficient because the plant roots are constantly exposed to oxygen which promotes healthy and fast-growing plants.
Aqua farming (or fish farming) can take a number of different forms; it can take place in open water (i.e. offshore), in onshore waterbodies (i.e. lakes, rivers and ponds), or it can be located onshore where the fish are housed within tanks, normally within purpose-built structures.
In general, offshore aqua farming would fall outside the scope of the land-based planning system. The determining factor would be if there was a physical attachment to the land. On such occasions a case-by-case assessment would be undertaken by the Department of Planning, in consultation with relevant Government Ministries.
Bermuda contains a small number of onshore waterbodies and it is highly unlikely that aqua farming would be supported within any of these locations. Nonetheless, the Bermuda Plan 2018 provides an adequate policy framework for the assessment of any such proposals.
In terms of aqua farming, this planning guidance note is primarily targeted at assisting in the assessment of planning applications for the onshore proposals.
Some of the known benefits of a successful land-based aqua farming operations are:
There are also a number of problems associated with aqua farms, including the production and safe disposal of effluents from the operation, as well as significant maintenance costs.
The existing planning policy framework provides strong support for the creation of healthy communities and local food production. The Bermuda Plan 2018 contains a chapter entitled “Healthy Communities” which has the following objective:
“HEA(4) To help build healthy and sustainable communities by supporting existing and new local food production.”
Objective HEA(4) of the Bermuda Plan 2018 is supplemented by policies HEA.5 and HEA.6, which outline the circumstances under which the construction of buildings associated with local food production would be acceptable and the zones where such uses would be permitted.
The Bermuda Plan 2018 also contains a policy (policy AGR.5) on methods of farming which require physical structures within the Agricultural Reserve (see section 5 of this document).
This guidance note is also applicable to land and buildings within the City of Hamilton. In terms of the existing City of Hamilton Plans 2015 and 2001 which cover the City, there is general support for a mix of development uses and strong support for the repurposing of vacant and underused office buildings which could provide opportunities for HAQ operations.
HAQ schemes could potentially be methods of food production which conveniently address three of the most significant issues experienced in Bermuda; the fact that we don’t produce enough food domestically to sustain our population (importing approximately 80% of our food supplies); the lack of land available to grow the crops that we require (combined with a resistance to utilise designated agricultural land for farming); and the fact that water can be scarce at certain times of the year. However, there are only a small number of examples on the Island at present which use these techniques (including a successful farming operation which also uses traditional land-based farming), and it remains to be seen as to whether there is sufficient appetite to enable these methods of farming to flourish in Bermuda.
In determining whether a hydroponic, aquaponic, aeroponic or aqua farming development is appropriate for a particular location, it is necessary to understand the physical form that each of the different operations can take, including scale, nature and design, as well as the environmental implications of each of these farming methods. Whilst there are differences between each of these techniques, there are a number of common characteristics which mean that they could potentially be acceptable within similar locations.
Policy HEA.5 of the Bermuda Plan 2018 sets out criteria to be used in the assessment of planning applications for hydroponics, vertical farming, aquaponics and aquafarming installations, as well as the Base Zones within which such activities may be permitted. This guidance note provides information in amplification of the criteria set out within policy HEA.5.
When operated commercially, the nature and setup of HAQ schemes is such that they share many of the same characteristics as industrial uses, to the extent that many such schemes around the world take place within industrial parks and warehouse units. Similarities include a requirement for large internal space, the need to operate large, bulky equipment and the need for good vehicular access for the delivery and collection of goods. The way in which these facilities operate and the associated environmental effects are the key factors in determining the appropriateness of locations for them.
In terms of environmental effects, the most obvious issues relate to amenity impacts through increased vehicular movements to and from these facilities (including by members of the public where there is a retail component) and the design impacts of any proposed structures upon the surrounding area. However, another critical consideration is the impact of wastewater from these systems. The water which circulates in these systems will have to be periodically replaced and, principally for hydroponic systems, this will mean the disposal of wastewater which can be rich in compounds of nitrogen and phosphorus. These compounds can cause contamination, particularly where disposal could impact upon surface water (e.g. ponds) and drinking water. It will therefore be necessary to consult with the Department of Environment and Natural Resources (Hydrogeology) in all instances to ensure that any operations are appropriately located and that suitable arrangements are in place for the disposal of wastewater (this may also require consultation with the Environmental Authority). This may have to be controlled by way of a water right and planning condition.
Policy HEA.5 of the Bermuda Plan 2018 confirms that HAQ schemes would be acceptable in principle, within any Development Base Zones and the Open Space Reserve Zone and sets out the overarching criteria which must be applied by the Board in considering such applications. Whilst there will be issues which are unique to specific zones, the general key issues which will determine the acceptability of HAQ developments will be the scale of the operation, and whether it is to be operated on a commercial basis (which will result in increased vehicular movements, particularly if there is a sales component). Consideration of these issues within the context of the objectives for the zone (set out within the Bermuda Plan 2018), will provide an indication as to whether the proposal would be appropriate.
Table 1 sets out guidance covering each of the zones within which HAQ schemes are permissible under the Bermuda Plan 2018 and the key policies and objectives of the Bermuda Plan 2018 which will be relevant to the assessment process.
HAQ schemes can successfully take place in a variety of different settings, including within urban environments such as the City of Hamilton. Within the City of Hamilton there is a high level of building vacancy rates and the use of some of these buildings for HAQ operations is supported in principle. However, there are some parts of the City which are more readily suited to such operations than others, for example, the Residential and Community District.
Table 2 sets out the guidance for HAQ proposals within the City and identifies the key issues and policies of the City of Hamilton Plan 2015 which will be applicable. Where design considerations form part of the assessment process, the general design policies of the City of Hamilton Plan 2015 will be applicable. It is also important to note that Table 2 has been designed to provide an indication of the key issues, policies and associated objectives and therefore does not identify every conceivable policy and objective which may be relevant to the assessment process.
The Use Class Order is not applicable within the area covered by the City of Hamilton Plan 2015 (see policy GEN.20) and therefore change of use applications will be required to establish a HAQ operation within the City. Where there is any dubiety as to whether a proposal would constitute a material change of use, advice should be sought from the Department of Planning.
The current development plan for the north eastern portion of the City of Hamilton is the City of Hamilton Plan 2015, however, the policies of the City of Hamilton Plan 2001 remain in effect for this area. The City of Hamilton 2001 provides support for a broad mix of uses within the City subject to amenity impacts, traffic implications and general compliance with the policies of the Plan (policy 1.1). Accordingly, there will be broad support for HAQ developments within North East Hamilton as set out within Table 3.
Agricultural land is a highly valued, finite resource on the Island and is afforded a high level of protection by the Development and Planning Act 1974 Heads of Protection and the Bermuda Plan 2018. There are 737 acres of land designated in the Bermuda Plan 2018 as Agricultural Reserve which includes land currently farmed and land with the potential to be farmed or used for agricultural purposes.
Whilst hydroponics, aquaponics, aeroponics and aqua farming are methods of farming, they differ from conventional farming techniques in that they generally require physical structures in order to effectively operate. If such developments were permitted within the Agricultural Reserve it could result in potential damage to top soil as well as the sterilization of agricultural land and mean that there would be less land available for conventional methods of farming. It may also result in pressure to repurpose buildings used for an HAQ development if those uses cease.
Policy AGR.5 specifically addresses the issue of physical structures associated with non-conventional methods of farming within the Agricultural Reserve:
“Any proposals for non-conventional methods of farming, including hydroponics, vertical farming, aquaponics and aqua farming, which require physical structures, will generally not be acceptable within the Agricultural Reserve unless the full extent of the proposed operation is within an existing building and is in accordance with the Department of Planning’s Hydroponics, Vertical Farming, Aquaponics and Aquafarming Guidance Note.”
This guidance note operates within the terms of this policy and therefore the only circumstances under which structures associated with the Agricultural Reserve can be used for HAQ operations would be where they would be within an existing building. However, there are a vast number of locations across the Island which would be suitable for HAQ operations, as indicated by Section 7 of this document.
In the assessment of applications for HAQ developments, the Development Applications Board may seek the views of a range of stakeholders. The list of stakeholders will vary depending on the specific nature and location of a proposal, however, they may include (this list is not exhaustive):
The Department of Planning is commencing work on preparing a schedule of sites across the Island which would be suitable for development. Once published, this schedule will provide details of specific sites, noting where HAQ operations could take place.
Letters of objection and/or representation should be emailed to firstname.lastname@example.org referencing the PLAN or SUB number in the subject line.