Diffuse Water Pollution from Rural Land Use
Summary of responses
The Diffuse Water Pollution from Rural Land Use consultation closed on Monday 13 March 2006. The number of responses received was 38, these are summarised below.
Overall, the strategy was well received with support for GBRs and a need to move from voluntary advice, e.g the PEPFAA code, to a statutory regime. The PEPFAA code, although being accepted as being a good source of information, was highlighted as perhaps not being acted upon as well as it could be. There was full support for the development of guidance, support and the promotion of voluntary action. The farm audit proposals were accepted as a potential measure with a mixed response for either adviser led or self/adviser led audits. A partnership approach with the relevant stakeholders in taking forward the strategy was recommended. There was great support for the introduction of catchment officers to assist with implementation of introduced measures. The view of the NFUS is that the farming industry is highly regulated already and, with further legislation, there is the threat of double jeopardy with there already being the potential to penalise up to 100 per cent of the SFP.
1. Do you agree that we have accurately identified the water quality issues that need to be addressed? If not, why and what supports your view?
Most responses agreed that the water quality issues were broadly identified.
2. Do you consider there are other problems not identified?
Responses included ;
- The effects of nutrient loading on biodiversity.
- Understanding the behaviour of N and P in ecosystems
- Understanding of ecotoxicity of pesticides.
- Effects of siltation on salmonid rivers
Non agricultural diffuse pollution was raised as a problem not identified although it was pointed out in the strategy that it would be given separate consideration.
3. What aspects do you consider may require regulation or to be more rigorously controlled using existing powers of enforcement?
There were varying responses ranging from;
· all activities, not already, should be regulated.
· where activities are identified as 'a risk', regulation is required.
· Current legislation should be proved to be ineffective first.
No individual aspects were identified, but the point was raised that there is no single piece of legislation which deals directly with diffuse pollution.
4. Do you consider that advice on water pollution risks, within the PEPFAA Code and/or the Forest and WaterGuidelines, is effective? If not, what else is required?
It was recognised that the PEPFAA code was an excellent source of information. However there were some doubts as to the actual implementation of the advice contained within the code. The PEPFAA Code/F&W Guidelines were considered a good template for the development of National GBRs.
5. Which measures to protect watercourses would you wish to see eligible for financial support under the planned Tier 3 of LMCs?
- Constructed wetlands
- Fencing off watercourses
- Alternative drinking supplies
- Riparian zones
- Nutrient budgets
- Pollution audits
- Awareness Initiatives
- Biobeds
- River restoration
6. Do you agree with the idea for self-audit/environmental checklist of the farm's environmental practice?
There was mixed reaction to this, but overall it was felt the concept of self audit was sound in principle but to be totally effective it would require the back up of some form of support. It was suggested a more prescriptive adviser audit would be vital for areas where there are identified problems with a less prescriptive self audit with support for other areas.
7. We think it is important to help farmers/foresters/land managers understand the likelihood of water pollution from their enterprise. What is most likely to be effective?
- Advice/guidance/training/codes of practice/voluntary initiative etc?
- Seminars/farm visits/catchment officers?
- Structured Auditing?
All of the above were considered to be of value, but advice/guidance/training/farm visit being disseminated, on either a 'one to one' or group basis, by some form of catchment officer was a popular response. Catchment officers were commented on in most responses as vital in the role of advice/guidance/awareness raising/seminars/farm visits in the implementation of any policy, voluntary and incentive measures
8. Do you agree that farming should be subject to a regulatory structure similar to that already planned for other activities under CAR?
Apart from a few exceptions there was general agreement that a similar regulatory structure to CAR should be introduced which initially concentrated on the 'light touch' approach of national GBRs.
9. Do you agree that measures should be introduced as early as possible to enable us to meet WFD Targets?
There is opinion that the 'correct' measures should be introduced as early as possible to keep in line with the requirements of WFD due to the long return period of some pollution reduction measures. It is thought the measures should be developed in conjunction with interested parties.
10. Are you content that there should be general binding rules (GBRs) for activities which contain potentially polluting practices?
The proposed use of GBRs was accepted as a viable method of control , using the PEPFAA Code as a basis. And developed in conjunction with stakeholders.
11. Do you agree that specific problems in "at risk" catchments should be dealt with through targeted GBRs to be developed in consultation with the industry?
The use of targeted GBRs was also thought to be acceptable, providing that the evidence base was thoroughly investigated and development was in conjunction with stakeholders.
12. Do you agree with the proposed approach of combining regulations (GBRs) with the development of guidance, support and the promotion of voluntary action?
A robust support mechanism was consider a necessity if a suite of GBRs was to be developed and adopted by all.
13. Do you agree that the proposed GBRs and a suite of supportive measures is the right approach? What should they include?
Catchment officers was the most popular method proposed in responses as they could then be utilised effectively to disseminate training and information.
- Catchment officers
- Stakeholder involvement
- Training
- Assessment of effectiveness of measures
- Targeted Advice
- Assessment of new technology
- Demonstration sites
14. How might the proposed approach best be developed?
Many of the respondees expressed a wish to be included in an stakeholder group to take forward the strategy.
- Considered and phased roll out
- Cost effectiveness of measures
- Use of supportive roles (SAC, FWAG)
- National steering group
- Specific sector groups e.g. forestry, leisure industry.
15. Are there any further factors we need to take into account?
The responses included some points noted below, some of which will be an integral part of the developing policy.
- Monitoring/evaluation
- Effects of policy and measures on the environment and rural sustainability.
- Relationship with other developing legislation.
- Costs of compliance.
- Roles and responsibilities.
- Economic incentives.
- Source control e.g. animal feedstuffs
16. How should the Executive work most effectively with the agricultural sector?
By effective dialogue with the key players; i.e NFUS, SRPBA, Scottish Crofting Foundation, and all relevant SEERAD departments. As well as other representative bodies such as the Crop Protection Association, Agricultural Industries Confederation and National Association of Agricultural Contractors.
17. Can a similar approach be used for forestry as for agriculture?
The forestry sector has already committed to engaging with the Executive, SEPA and others in the process of developing a workable and proportionate set of regulations, including GBRs, which achieve the objectives of the Water Framework Directive.