Examination of Witnesses(Questions 480-499)
MR MICHAEL
PASKE, DR
ANDREW CLARK
AND MR
MICHAEL PAYNE
WEDNESDAY 4 DECEMBER 2002
480. In terms of this Directive and your farming
practices, what powers do the Agency have over you? They cannot
make you do things, can they?
(Dr Clark) They can license quite a range at the present
moment in terms of discharge consents, abstraction, a water resource
use. Where I think they are weaker in terms of regulatory impact
is in terms of looking at diffuse pollution. I would argue, and
have argued to them many times, that diffuse pollution is not
the sort of thing you can regulate about. In actual fact, because
of its nature, you have to use other policy mechanisms to get
to address that and you have to deal with it in partnership rather
than with a big stick.
481. Let us talk about diffuse pollution for
a moment or two. This is the big risk, the big area where we need
to have some change. I am not entirely clear how it is going to
happen. How do you think it is going to happen?
(Dr Clark) I think there is a whole range of different
things which we can do in terms of diffuse pollution. First of
all, there is a cultural change. We have to make it clear to farmers
that diffuse pollution is not something you can necessarily see
like a bust slurry wall or something like that; it is often quite
insidious. So there is a cultural change which has to happen here
within the farming community and we think the best way to get
to that is through demonstration projects, through best practice,
through information, advice. We think that the entry level scheme,
the broad and shallow scheme, is going to have a big impact here,
because that is going to help farmers implement spring cropping,
under-sowing, using buffer strips, activities such as that. Perhaps
most importantly it is a case of identifying fields and areas
of farms which are vulnerable to soil erosion. If we can identify
ways of actually conserving soil on farms, so it does not move
off the field, then at a stroke we can sort out some of the problems
in terms of phosphate movement and silt movement into water courses.
So it is a case of trying to sort things out at source, and that
is about agricultural practice and it is about how we can perhaps
use minimum tillage instead of ploughing, timing of cultivations,
when you drill and what the soil condition. It is really quite
technical stuff, agronomic practice.
Chairman
482. We saw a very interesting machine at Smithfield
designed to do precisely that, retain the water in sort of divots.
(Dr Clark) Yes, I have seen that.
Paddy Tipping
483. This is about good practice and promoting
good practice. You promote good practice. How can you actually
make it happen? Some people, dare I say, in the farming industry
are a bit resistant to change and new practices. How are we going
to make these changes in the industry?
(Mr Paske) That is what we call incentivisation, is
it not, and it is a very difficult one, to actually incentivise.
I think peer pressure has a lot to do with it. I think there are
far more good examples of how we are having good practice in agriculture.
Unfortunately the one that makes the headlines is the one that
is always the worst practice. It is our job to make sure that
the worst offenders are brought up to the levels of the rest of
us, in that sense, and that is obviously what we as an organisation
try to do, but it is incentivisation.
(Mr Payne) I think we probably have lessons to learn
from some other countries. In the States, for example, there is
a far less regulatory approach and a far more local community
approach, where farmers are proud to put up signs on their land
to say: "I am part of such and such a catchment management
programme. We are aiming to improve water quality and we are doing
this, this and this." Local groups have a pride in their
local areas. It is a different culture from the one that we have
at the moment, where we live in terror of a policeman knocking
at the door. I am sure that we are not going to abandon one and
go to the other, but there is a blend of approaches and we may
not always have got it right in the past.
484. One of the incentives is a financial incentive.
Is it your view, in a sense, that this whole Directive is going
to speed the movement between Pillar I payments (payments for
subsidies) to Pillar II payments (payments for environmental gain).
Do you see this as a driver for reform in agricultural policy?
(Mr Paske) I think the driver for reform is there.
Certainly we support the driver for reform. But you have raised
a very interesting angle, if I can put it that way, Mr Tipping,
because obviously the whole question of the way the CAP is looked
upon I think should have particular relevance to this particular
piece of regulation, and undoubtedly at the present moment it
does not. If there are going to be wholesale changes in the way
that we farm, then the CAP, which is obviously the method which
goes towards in some regards paying some of our costs, needs to
be able to take that into consideration. I think that is something
which is not being done as effectively as it might be.
485. Finally, are you confident that DEFRA see
this and that the Commission see this?
(Mr Paske) No, I am not. I think one of the problems
that I have with DEFRA is that they have a very small team looking
at the whole of this very important and very detailed piece of
regulation and one of the things that concerns me greatly is their
interface in Europe. We are going to have to rely on them to be
able to give us information, and it is simply because the stakeholders
are not involved in all of those levels of discussion and I have
genuine concerns about that. Andrew, I do not know if you want
to add anything.
(Dr Clark) Yes. We obviously have a role through our
European farming organisation COPA to try to influence the agenda
in Europe, but it is quite clear that the agenda is happening
in Europe. That is where definitions are being made right at this
present moment and DEFRA has an absolutely critical role in terms
of picking up developing discussions and alerting stakeholders
as soon as possible. We are a relatively small organisation, the
NFU, though we are one of the larger lobbying organisations within
the UK. As I say, with the legislative load that is coming along
on the environment, this is just one of the pieces of legislation
that we have to keep an eye on, so it is very important that DEFRA
makes sure that all stakeholders, including the NFU, are engaged
in developing the process rather than perhaps consult when decisions
have already been made.
(Mr Paske) Mr Tipping, if I could just add one thing
on that. In the evidence we have submitted to you, we have actually
given you an example of where we have spotted something which
is of great concern, voiced are opinion, lobbied hard, had it
removed. It came out and then at a higher level it was put back
in again. That is the sort of thing which we rely on DEFRA to
watch out for, those sorts situations.
Mrs Shephard
486. Would you not agree, though, that the NFU
has a practical and key role in this area, in that you are promoting,
I think you said four, pilot areas; you do have contact with your
membership in a way that absolutely no other organisation does;
and you too could help promote good practice.
(Mr Paske) Indeed.
487. No doubt it would help if you knew where
the goal posts are going to be.
(Mr Paske) Thank you very much for putting it in that
way. It is something I absolutely agree with, yes.
Phil Sawford
488. You refer to diffuse pollution and that
is a huge problem in trying to track that back and find out who
is responsible for that. You say that we need information, we
need better advice, but we have a situation where the Environment
Agency may well be the body that is expected to offer that information,
advice, guidance and also be the regulatory body. Is that a difficult
thing?
(Mr Paske) Yes, it is, as I have said to you before.
It is a very difficult situation. Just imagine it yourself: you
invite somebody to come onto your farm to give you advice, they
go away and the next thing you get is an enforcement visit because
you have been doing something wrong. That, believe it or not,
has happened on many occasions.
489. The same people. The whole issue of diffuse
pollution is based on imprecise science as well.
(Mr Paske) So much so that, I think again in our evidence
we submitted to you, there is this classic situation where one
scientist has come out and said: "If we do nothing we are
still not going to achieve the objectives that we have been set."
But I am sure my colleagues have something to say on that.
(Mr Payne) I do not want to go too much into semantics
on this, but there is a question about diffuse pollution, about
how much the land use you choose will have an inevitable effect
on water quality. Trees are a good example because nobody does
much to trees. They just grow, they are not fertilised or managed
very much, yet they manage to create considerable problems in
some catchments, partly through the amount of water they remove,
partly because they are good at scavenging atmospheric pollution
out of the air, and they generate problems through acidification
of waters—release of aluminium, things of this sort. But
if you are going to have trees and tree plantation, and we are
going to produce some of our timber, those sort of effects are
to some extent inevitable. And the same is true of agriculture.
If we are going to have any kind of productive agriculture, it
does involve feeding the plants, it involves nutrients moving
through the soil, and, it is not in a factory, you cannot prevent
some degree of leakage. How much are we prepared to accept it?
Are we going to accept that we have agriculture and we have a
degree of leakage of things like nutrients, and are we going to
set our standards accordingly? It is a question of how much is
pollution and how much is just a change through land use.
490. So farmers, unlike, say, a pharmaceutical
industry or food processing, are not in a controlled environment:
where they are is where they are.
(Mr Payne) That is right.
491. The natural surroundings, the natural resources,
the natural chemicals could create difficulties between you and
the regulator basically.
(Mr Payne) They could do, depending on how the standard
is set. We already have a problem with the Nitrates Directive,
that the standard has been set in a way which is incompatible
with agriculture under drier conditions, in the way that we practice
agriculture at the moment, or it is in danger of being—it
depends how it is implemented to some extent. Those sort of problems.
Hopefully we will not have such a problem with the Water Framework
Directive because that Directive only asks us to change things
which are causing an actual genuine change/detraction from the
ecological quality of water, whereas the Nitrate Directive requires
change regardless of whether there is any impact on ecology or
not. The Water Framework Directive is much more logical in that
sense, but what you say is true. Our predecessors in giving evidence
made the point that it is technically possible to remove almost
anything from water on an end-of-pipe system, but there is no
way you can do that in agriculture, not in an end-pipe solution.
492. Is the science we have adequate to establish
the point, the limit. I suppose, "We would not have started
from here" is always . . .! But this is where we are. Is
the science up to it? Or do we just use this as an excuse?—you
know, "Not me, guv. It is not my fault the next farm has
trees" and "It is not my fault that there is a factory
three miles away" and everybody passes the buck and says,
"That is not our diffuse pollution" and points the finger
at somebody else.
(Mr Payne) There are some interesting questions around
that. The science is good in some areas, not so good in others.
I referred earlier to the assessment of costs and benefits which
have been made by consultants and that identified the very different
costs to different sectors of controlling the same pollutant.
If we think again of nitrates, and we compare the cost of removing
nitrate from sewage and removing it from agriculture, the costs
are different. One is cheaper than the other. The same is true
of phosphate, although the balance is reversed. It introduces
some very interesting choices about how we are going to manage
this type of situation. If we are aiming for a particular target,
are we going to share the misery equally or are we going to go
for wherever is cheaper and expect that sector to pick up the
tab? Or do we have some kind of burden sharing? There is set of
very interesting questions here about how we should approach it.
We are very unsophisticated in this area at the moment.
Chairman
493. Severn Trent has told us it understands
the Government is going to implement everything at the latest
legal date. You point out that in fact there is scope to extend
the timescale. The Government appears to be not wishing to be
accused of gold-plating by advancing the dates, though some of
the organisations who have given evidence would clearly like to
see that. What is your understanding about the Government intentions
about the implementation dates? Are you making a real case for
invoking the possibility of extension?
(Mr Paske) I will let Michael answer that, if I may,
Chairman, but one of the things that is important there is the
whole cost factor again. Obviously one of the things that we do
feel is that the implementation date means that there is a very
heavy burden of cost during that period. Michael, do you want
to go on to the other point.
(Mr Payne) I think our understanding is that on the
straightforward level Government does intend to implement by the
date required in the Directive and not before, but many of the
key questions are not when it implements but what it implements,
and that we do not know. Until we know that, we could not make
a case for delay, the derogation for delay, because we simply
do not know what we are going to be asked to do. If we are not
asked to do too much, it could all be achieved with best agricultural
practice, then we can work along with all the other partners and
stakeholders to deliver the results. But if we are going to be
asked to change our farming systems very dramatically, say, for
the sake of argument, not to grow sugar beet in this country—not
that sugar beet is a problem, so far as I am aware, but to take
that as a non-controversial example because it is not generating
those problems—it would have a huge impact.
Mrs Shephard
494. Non-controversial?
(Mr Payne) Because it is not realistic.
Chairman
495. We are not moving into the "Anything
but arms" debate.
(Mr Paske) That is a pity.
Paddy Tipping
496. In a sense, there is danger that we might
try to micro-manage things, but there are different environmental
factors across the country. In a sense, the good farming management
practices that have been adopted in different parts of the country
are going to be different.
(Mr Paske) They are. Of course you are familiar with
the voluntary initiative and the work that is going on there and
in the catchment areas. Of course we are finding already that
that is why we have 17 or so catchments in which we are doing
these trials because different requirements are required by different
farming practices in different areas as well. So we are already
in that regard going down that route, but that is something which
we shall have to look at fairly closely with the EU Water Framework
Directive as well.
497. Mr Payne told us earlier on about the signs
around the area that were a community initiative. Are there marketing
opportunities in the Directive, that we are producing more environmentally
friendly food?
(Mr Paske) Our experience in that is that there certainly
are some people who would pay extra money for those sorts of products.
The classic situation in that has been in the past organic. I
say in the past because, sadly, the premiums that were available
in that particular form of farming have now disappeared. We need
a great education of the great British public if we are going
to get them to pay more money for their food simply because it
is coming from a system which is more in keeping with what they
tell us they want. It is a very difficult one to be able to quantify.
498. In a sense, your message to the Committee
has been: These will have bottom line costs which we cannot pass
on.
(Mr Paske) That is exactly right.
Chairman
499. The problems you are experiencing are presumably
being experienced by farmers right across the European Union and,
indeed, the applicant almost Member States. They are presumably
asking exactly the same questions.
(Mr Paske) Could I just interrupt you, Chairman. We
referred earlier on to our involvement in COPA COGECA, which is
the association in Europe for farming unions and also producer
groups. We are taking the lead in that simply because it would
appear that our colleagues in the rest of the Member States are
really not up to speed on what is actually going on with this
particular piece of regulation.
|
