To:
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Environment
& Sustainability Committee
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Date:
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27th
May 2015
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Ref:
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Circulation:
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Contact:
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Rachel
Lewis-Davies
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Tel:
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01982
554200
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Fax:
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Email:
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Rachel.lewis-davies@nfu.org.uk
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NFU
Cymru response to Environment & Sustainability Committee
Inquiry -
Water
Quality
- NFU Cymru
welcomes the opportunity to respond to the Environment &
Sustainability Committee Inquiry into water quality which seeks to
examine progress towards meeting the statutory obligations under
the Water Framework Directive and Bathing Water
Directive.
- Currently just
over one third of our water bodies achieve good ecological status
under the terms of the Water Framework Directive. Reasons for
failure are complex and varied and were summarised in the Welsh
Government Consultation Document ‘A Water Strategy for
Wales’ (2014)
- Evidence
suggests that there are a range of issues and sectors influencing
water quality in Wales and Water Framework Directive Failures
attributable to agricultural pollution are shown to be between
14-15%.
- It is clear
that efforts to address water quality using a single issue approach
will not deliver the necessary improvements to deliver on Water
Framework Directive goals, in particular, the requirement to meet
100% compliance with the Directive by 2021. That said, NFU
Cymru acknowledges the role that the agricultural industry has in
improving water quality through addressing issues relating to
agricultural pollution.
- We would stress
that in agricultural terms the word pollution can be considered
inappropriate to the extent that often what is meant is raised
nutrient levels. We would highlight that failures are higher
due to changes to monitoring which now include assessment of both
biological and chemical status. An increasing issue with
Invasive Non-Native Species in riparian habitats which leaves
riversides totally devoid of vegetation in winter as these plants
dieback also contributes to an exacerbation of the
problem.
- NFU Cymru would
take this opportunity to highlight the practical action that
farmers are taking on a voluntary basis to improve water
quality. This includes:
-
- Reductions in
fertiliser application rates since 1980s – 35% less nitrogen
and 60% less phosphates – whilst achieving similar crop
yields
- Almost
560,000ha of land under Glastir agri-environment contract that
benefit water and the wider environment
- Over 275,000ha
of land under management options aimed at improving water quality
under Glastir Advanced
- 310,000m of
streamside corridor established through the Glastir Scheme
alone
- Approximately
£16m of investment in farm infrastructure to improve water
quality
- In excess of
1500 nutrient management plans part funded through Farming Connect,
with a further 400 funded as part of Glastir Advanced. (The
number of farmers with nutrient management plans developed outside
of these mechanisms is not known)
- Three quarters
of the land area of Wales under voluntary farm assurance schemes
which require inspection for compliance at 12-18 month intervals
and which have clear requirements on manure, nutrient and pesticide
management.
- In addition
there are initiatives such as the recent innovative project led
by Dwr
Cymru–Welsh Water aimed at reducing levels of the grassland
herbicide MCPA in the River Teifi and Upper River Wye catchment
areas. This initiative supports farmers to try alternative
methods of controlling rushes and weeds through offering the free
hire of weed-wiper equipment using Glyphoshate between April and
October 2015.
- The significant
actions to improve water quality have led to acknowledged
successes. The reversal in decline of the otter population in
Wales arising from improved water quality being a case in point.
The recent clean beaches awards are testimony to improvements to
the quality of bathing waters
- NFU Cymru
recognises the clear role that farmers have to play in contributing
to further and sustained improvements in water quality in the years
ahead.
- NFU Cymru are
strong advocates of appropriate interventions where poor practices
are responsible. It has been our long-held view that any
approach must be evidence-based, providing local solutions to local
problems working in partnership with industry to be
effective.
- NFU Cymru would
highlight the significant mechanisms at our disposal, which with
some thoughtful design and implementation, have the potential to
make very valid contributions to water quality.
- The Rural
Development Programme (RDP) (2014-2020) which has recently been
formally adopted following approval by the Commission offers, in
our view, a number of clear opportunities.
- We understand
that 60% of the £957m budget has been allocated to land-based
measures via the Glastir scheme which has six strategic objectives,
including ‘To increase the
level of investment into measures to manage our water resources
effectively with the aim of contributing towards an improvement in
water quality in Wales and to meeting our obligations under the
Water Framework Directive’.
- Glastir has a
number of elements including Entry, Advanced and Commons with a
number of new elements proposed as we enter the new RDP which
include Small Grants and Part-Farm/Habitat Network
Schemes.
- It has been the
long-held view of NFU Cymru that participation in agri-environment
schemes should be voluntary but that the scope of the scheme should
be such as to be open to any farmer irrespective of location or
farm enterprise type. NFU Cymru believes that the ambition
for Glastir should be to be simple, uncomplicated and transparent
for the applicant with activity that is practical and achievable to
implement on the ground. This is vital if the strategic
objectives of the scheme are to be delivered.
- We would
express some concern at proposals which appear to de-emphasise the
entry level scheme which is accessible to all in favour of more
targeted interventions through Glastir Advanced. We would
reiterate that action on the ground relies on farmer
participation.
- We would
further highlight that the Glastir Small Grants and
Part-Farm/Habitat Network Schemes offer new and significant
opportunities for environmental action, particularly in the area of
water quality, by engaging agricultural businesses (and sectors)
not ‘traditionally’ involved in agri-environment work.
We are disappointed that despite the budget allocation to
these measures in the RDP that the roll-out of these elements is
likely to be significantly delayed.
- The new
Sustainable Production Grant Scheme offers a further opportunity
for measurable improvements in water quality, through 40% funding
for a range of capital items such as slurry/manure storage and
clean/dirty water separation. The environmental benefits of
such investments are clearly understood, such investments leave a
legacy beyond the lifespan of any project and farmer participation
should, therefore, be actively encouraged. It is our strong
view that the Sustainable Production Grant Scheme should be clear
and easily accessible, the application process should be
straightforward for farmers and not add additional, unnecessary
costs.
- We cannot
emphasise enough that an application process that is shrouded in
complexity will represent a barrier to uptake and ultimately lead
to delayed progress in this area.
- The Knowledge
Transfer, Innovation and Advisory Service under the Wales Rural
Development Programme 2014-2020 (Farming Connect) offers a further
opportunity. We understand that Farming Connect will receive
a budget allocation of £45m over the programme period to
increase the emphasis on business focussed behaviour and therefore
improve the profitability, competitiveness and environmental
performance of farm, forestry and food businesses through knowledge
transfer, innovation and advice.
- On the issue of
water quality, in our view, Farming Connect must now move on from
its current approach of ‘awareness raising’ of generic
issues relating to water quality, to providing advice to support
farmers to take action in targeted areas in conjunction with the
other measures available. This requires the concerted effort
and co-ordination of all parties including Natural Resources Wales,
Welsh Government and contractors which, hitherto, has been
lacking.
- It is our view
that improved performance by Farming Connect in this area could
support Natural Resources Wales whose key challenge, two years on
from establishment, remains how to effectively engage with the
18,000 or so farm businesses across Wales who manage 80% of the
total land area.
- These
businesses tend to be sole traders or partnerships that find
themselves operating in a highly complex regulatory context –
of which environmental management is just one of a number of
important facets.
- We would
reiterate our concerns that the merger of three organisations and
subsequent restructuring has led to the loss of a number of key
personnel, particularly those who were employed previously by
Environment Agency Wales. Others with suitable expertise and
experience, whilst still employed within NRW, appear to be
consigned to different roles and are less accessible to farmers who
would have, in the past, approached them for advice on regulation
and best practice.
- In terms of
making progress on this issue, NFU Cymru is of
the view that a service similar to the Farm Liaison Service within
Welsh Government, with knowledgeable and trusted staff within NRW
providing practical advice and support on both regulation and best
practice across a range of issues, including water quality, would
deliver beneficial outcomes.
- Turning to the
issue of effectiveness of monitoring and enforcement, NFU Cymru
would highlight the need for any monitoring system to be
sufficiently robust as to be able to take into account exceptional
weather conditions which are outside anyone’s control and
which in all probability will increase in frequency in future
years.
- We
would also take this opportunity to reiterate that NFU Cymru does
not support additional regulation or ‘gold-plating’ of
regulation which is a blunt instrument which adds cost and places
farmers in Wales at a competitive disadvantage to our EU
counterparts. It is our view that far greater benefit can be
achieved through voluntary action working in partnership with
industry to drive improvements in water quality as described
above.
- We do not,
therefore, support the introduction of additional regulation
including general binding rules and would highlight farmers in
Wales are already governed by a raft of regulations including
strict rules on the use and disposal of pesticides and on the use
and disposal of sheep dips. Cross Compliance requirements
established through the basic payment scheme deliver baseline
standards and are subject to an inspection regime by Rural Payments
Wales. Those participating in agri-environment schemes also
follow the rules set out in the Whole Farm Code. It is our
view that the introduction of General Binding Rules would
effectively result in the introduction of another layer of
regulation and NFU Cymru would conclude that it would be premature
for NRW to have any additional regulatory powers at this
stage.
- The Inquiry
into water quality is also timely as the Review of the Nitrates
Directive is underway with revised maps and the potential for
additional designated areas in Wales expected in the coming
months. We would highlight the very significant restrictions
placed on farmers in NVZ areas for the benefit of water
quality. NFU Cymru is very keen to work with Welsh Government
and NRW in a partnership approach to identify areas where voluntary
action now could prevent the need for designation in the
future. NFU Cymru would suggest that in such instances a
concerted multi-agency effort is required to make targeted efforts
to support the farmers to take action in these
areas.
- To summarise,
NFU Cymru would agree that improvements in water quality are
necessary if Wales is to meet the obligations of the Water
Framework Directive. The agricultural industry has a clear
role to play in making improvements to the 15% of Water Framework
Directive failures currently attributable to the sector. We
are able to identify a clear number of opportunities available to
drive improvements in water quality including a number of measures
in the new Rural Development Programme. NFU Cymru is very
keen to work with Welsh Government to see the development and
implementation of schemes that are fit for purpose, engaging to
farmers and deliver transformational change.
- We note the
invitation to submit oral evidence to the Committee on Wednesday
10th June 2015. NFU Cymru looks forward to giving
evidence at this event.