Memorandum submitted by Broadland Agricultural
Water Abstractors Group (BAWAG)
INTRODUCTION
1. BAWAG is an association of over 100 agricultural
and horticultural water abstractors based around the Norfolk Broads
in East Anglia. BAWAG was founded in 1997. It represents the water
interests of its members and acts as a forum for discussion of
sustainable agricultural water management. BAWAG encourages its
members to both have a greater involvement in water policy issues
and to strive for wise and sustainable use of water resources.
2. We welcome the chance to submit evidence
to this Select Committee inquiry, as the Water Framework Directive
(WFD) will have a fundamental impact on our members' management
of water.
KEY POINTS
3. BAWAG supports the sustainable management
of water resources and therefore we support the introduction of
the WFD.
4. BAWAG is concerned that there has been
very little dissemination of information on the Directive to the
agricultural and horticultural community.
5. BAWAG believes that there is an essential
need for farmers and horticulturalists to receive free technical
advice and assistance on water management in order to meet the
requirements of the WFD.
6. BAWAG is concerned that there will be
a disproportionate burden on the agricultural and horticultural
community to deliver the WFD aims.
7. BAWAG believes that rural funds should
be readily available to assist farmers and horticulturalists to
improve their water management techniques. And that this will
aid in the delivery of the WFD objectives.
8. BAWAG is concerned that the approach
to agricultural regulation in England is piecemeal and that there
need to be definitive policies related to the agricultural use
of water.
9. In order to meet the requirements of
the WFD we would like to see a range of measures instigated for
farm water management. Alongside the legislation and regulation
required to deliver the WFD, BAWAG members are willing to take
on certain initiatives on a voluntary basis, such as monitoring
of on farm water levels, water auditing and water efficiency measures,
however these actions work best when augmented or part-funded
by grant aid and free advice.
10. BAWAG would like to see the Government
undertake a full regulatory impact assessment for the WFD.
11. BAWAG is keen to play its part in delivering
the WFD objectives but we would like the Government to meet us
half way.
INFORMING THE
AGRICULTURAL SECTOR
ABOUT THE
DIRECTIVE
12. Agriculture and horticulture will play
a key role in delivering the WFD. BAWAG members will strive to
assist in the delivery of the aims of the Directive. However to
fully deliver the Directive will require the Government to develop
an outreach programme to the agricultural and horticultural community
at a local catchment level. It is our understanding that Article
14 requires Member States to "inform, consult and actively
involve" stakeholders in the development of the River Basin
District management plans, we believe that the Government should
be directing resources to address this issue now and at the very
least producing information leaflets specifically targeted at
the agricultural community. However, to date, our members have
received no information about the Directive, surely with the Government
stressing the importance of linking agriculture and environmental
protection we should at least be kept informed.
PROVIDING FINANCIAL
ASSISTANCE AND
ADVICE TO
IMPROVE FARM
WATER MANAGEMENT
13. Whilst we understand that the use of
Government funds to assist in meeting European Directives is prohibited,
there is a need to help farmers improve water management in general,
and an incidental consequence of this will be to meet some of
the WFD requirements.
14. For instance BAWAG believes that the
Government should provide funds for large-scale winter storage
reservoir provision in East Anglia. This will reduce agricultural
summer abstraction and is the most sustainable way to address
the water deficit highlighted in the Environment Agency's regional
Water Strategy. However BAWAG is concerned that RES and RDR funds
that were available for farm water management in East Anglia have
been relocated elsewhere.
15. And at a more basic level we would like
to see the reintroduction of free on-farm environmental advice
and assistance with water audits and water management.
TIMETABLE FOR
IMPLEMENTATION OF
THE DIRECTIVE
16. BAWAG would like to see swifter action
by Government to start to undertake some of the assessments required
under the WFD. Farming and horticultural are long term businesses
with high levels of investment that have long payback periods.
By comparison the WFD timetable is short and we would like to
see the Government acting sooner rather than later to ensure that
we are given sufficient warning of the actions we are expected
to undertake. This will also enable our members to begin to take
action now on a voluntary basis.
REGULATORY IMPACT
ASSESSMENT
17. The regulatory impact assessment produced
by DEFRA for the WFD is woefully inadequate. By contrast the Scottish
Executive has recently produced a report on the impact of the
WFD regulatory measures for irrigation specifically for the potato
sector, which is over 120 pages long.
CAPACITY OF
DEFRA AND THE
ENVIRONMENT AGENCY
TO DELIVER
THE DIRECTIVE
18. We are concerned that both the Environment
Agency and English Nature have insufficient resources to carry
out the monitoring and assessments required under WFD. We have
noted that, in assessments carried out under the Habitats Directive,
a lack of information often leads to a reduction or removal of
an abstraction licence, as the "precautionary principle"
is invoked. We want to see proper assessments carried out to ensure
that decisions are based on sound science, this is particularly
pertinent in ecological assessment where an "expert"
opinion based on no data can lead to a loss of licence, with significant
economic and social consequences.
19. We are concerned that inadequate attention
has been given to the planning of the WFD implementation; we do
not believe that sufficient resources are in place for the Directive
to be implemented in the most economic and efficient manner.
20. It is also clear that the Government
intends to implement the Directive at the last possible moment;
this is because of the fear of supposed "gold-plating".
There are a number of deadlines for implementation laid out in
the WFD and we believe it would be better to use optimisation
techniques to understand when to carry out certain actions to
deliver the WFD in the most efficient manner, rather than to take
a dogmatic approach to minimised implementation.
21. The Nitrates Directive and Freshwater
Fish Directive show how the approach of minimal implementation
at the last possible moment can lead to infraction proceedings.
We would rather see implementation that delivers the objectives
of the WFD; if the Government has seen fit to agree the WFD then
it surely it is worth implementing the Directive properly.
INTERNATIONAL COMPARISONS
22. Whilst we support the implementation
of the WFD, BAWAG members are concerned that other EU countries
should implement the Directive in the same way, otherwise there
could be internal competitive distortions between Member States.
For instance the Spanish Government is currently planning to implement
a large scale water transfer to provide water for southern Spanish
farmers, this is clearly illegal under the WFD and we urge the
UK Government to oppose the use of EU structural funds in support
of this plan, otherwise Spanish farmers will be given an unfair
competitive advantage and the environment will be severely damaged.
It would be ironic if restrictions on abstraction in East Anglia
due to the WFD lead to businesses relocating to Southern Spain.
23. The UK Government must either work within
the EU to ensure there is a level playing field in the implementation
of Directive, by pressing for action against the Spanish Plan,
or it must provide UK agriculture with grants for water supplies
that enable them to compete.
24. Also we are concerned that farmers in
the USA are being exempted from environmental legislation (eg
under the "Right to Farm" laws) and we would like to
the UK Government pressing for the WTO to set environmental compliance
standards that will protect UK production from cheap imports with
higher environmental impacts.
ROLE OF
ENVIRONMENT AGENCY
25. The Government should instruct the Environment
Agency to recognise its duty with regard to sustainability. Its
policies with regard to farming abstraction licences are currently
impacting on the local economy and on local communities and employment.
We do not wish them to ignore the need for environmental protection,
we share these aims and indeed many of our members also rent out
holiday accommodation, which is reliant on the high environmental
quality of the area. However we would like the Agency to balance
the recommendations of English Nature against those of the Regional
Development Agency and other bodies.
26. Whilst we recognise the Environment
Agency's expertise in water issues and environmental protection,
it is our understanding that the WFD is about sustainable water
management rather than simple environmental protection. We are
concerned that the Environment Agency will take an environmental
protectionist view of Directive implementation rather than a sustainable
development view.
27. This is already being seen in the CAMS
process, which the Agency sees as forming part of the WFD implementation.
Rather than looking at water resources in catchments holistically
and considering how recharge can be enhanced, such as requiring
developers to use permeable surfaces that allow water to infiltrate,
or increasing household water efficiency, the Environment Agency
are focussing solely on reducing abstraction licences.
28. The reduction of abstraction licences
will hit the farming community hardest and will cost jobs and
money in the rural economy. Whilst we recognise that there may
have to be some economic trade-offs to safeguard the environment,
it is our understanding that true sustainable development is about
developing alternative approaches that benefit the environment,
economy and society, ie developing better approaches to planning
and land-use rather than just restricting abstraction.
29. We are also concerned that farmers may
be easy targets for licence reductions, as individual farmers
do not have the financial or lobbying power of water companies
or environmental NGOs.
CONCLUSIONS
30. East Anglia is the most intensively
farmed region in Britain. The area produces irrigated crops, such
as sugar beet and potatoes and irrigated horticultural produce.
None of this irrigated production is supported by subsidies. Irrigation
methods in the area are amongst the most advanced in the world.
This means that BAWAG members are able to deliver high quality
food, to higher environmental standards than most imports and
compared to production in other areas of the UK where soil types
and climatic conditions restrict production levels and thus reduce
irrigation efficiency. This also has an impact on the use of crop
protection products and fertilisers.
31. If implemented correctly the Water Framework
Directive should assist farmers in their efforts to improve water
efficiency and water management in a way that contributes to sustainable
development. However, we have seen no effort from either the Government
or the Environment Agency to engage farmers in a real debate on
improving water management. The sort of things we would like to
see are:
32. Full explanation, consultation and involvement
of farmers in the implementation of the Water Framework Directive.
33. A real regulatory impact assessment
of the impact of the Water Framework Directive on agricultural
irrigation. This must give full consideration of social and economic
impacts of environmental actions such as licence reductions.
34. Grants for winter storage reservoirs
and free on-farm advice for nutrient management plans and water
audits and guidance on how to improve farm water management.
35. Government action at a European Union
level to ensure uniform application of environmental Directives.
And Government pressure on WTO to ensure imports from outside
the EU meet the same environmental criteria.
36. Farming to be given priority for water
use in East Anglia and a precautionary principle approach to farm
employment levels in East Anglia, in recognition of its primary
economic importance in the region. This would mean that impacts
on farming water resources would have to be considered in any
new development proposals and when water companies build new supply
infrastructure.
BAWAG
20 September 2002
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