Memorandum submitted by the Salmon and
Trout Association
EXECUTIVE SUMMARY
1. Thank you for giving the Salmon and Trout
Association (S&TA) the opportunity to respond to the inquiry
into the Implementation of the Nitrates Directive in England.
The S&TA is an international organisation representing the
interests of 100,000 individual and club-based game anglers, fishery
owners, managers and affiliated trades throughout the United Kingdom.
We are especially concerned with promoting and communicating the
environmental, social and economic benefits of game angling and
fisheries management.
2. Eutrophication is a very serious problem
to waterbodies, with nitrates and phosphates from agriculture
being the principal contributor. Eutrophication destroys aquatic
food-webs and biological diversity, by starving the organisms
of oxygen. Treatments and remedies are often impractical, temporary
and costly; making it imperative that we treat the causes of eutrophication
to prevent it occurring in our waterbodies in the first place.
We therefore support integrated, holistic management of diffuse
pollution, and believe that nitrates and phosphates should be
considered together, as effective prevention of eutrophication
requires all nutrient discharges to be controlled.
3. Overall the S&TA supports the revised
Action Plan proposals to reduce fertiliser and manure usage on
farms, and improve slurry storage capacities. We support applying
the revised Action Programme throughout England, and strongly
support the introduction of the revised plans in April 2008.
4. We believe the enforcement of new and
existing regulations is an important step in achieving successful
reductions in diffuse pollution. To achieve this we wish to see
greater cross-compliance across the Common Agricultural Policy
(CAP), with the use of more targeted General Agricultural and
Environmental Conditions (GAECs). This would increase the farmer's
incentives to comply, and add leverage to the competent authority's
ability to reduce diffuse agricultural pollution. We would also
like Defra to identify from where the necessary resources to facilitate
this Directive will come.
Our responses to the individual questions set
out in the inquiry are as follows:
5. Has Defra's implementation of the 1991
Directive been adequate; and how have levels of nitrate pollution
changed since the Directive came into effect? How effective has
the current Action Programme been in reducing nitrate pollution?
By Defra's own admission nitrate levels generally
have shown little reduction in spite of the regulations imposed
under the 1991 Nitrate Directive. We feel this is because the
current measures and their limited coverage have not been adequate.
This is made worse by the decreasing resources being made available
to the regulating authority, the Environment Agency, to monitor
and enforce the already limited regulations adequately.
6. Defra says that the area designated as
Nitrate Vulnerable Zones (NVZ) needs to increase from 55% to 70%
of England: is it right?
The S&TA supports Defra's proposals to extend
the area beyond the current 55%, as this is clearly inadequate.
However, we feel there are excellent reasons for extending the
Programme's measures throughout the whole of England.
7. Whether the proposed Nitrates Action Programme
measures should apply throughout the whole of England, rather
than only on land designated as Nitrate Vulnerable Zones
The S&TA fully supports applying the revised
Action Programme throughout England. We feel this will create
a level playing field for all farmers and avoid problems with
de-designation and determining boundaries. A 100% designation
would send a clear and simple message to everyone that this is
a serious problem which requires attention now. There also appears
to be difficulties identifying the correct land to designate,
therefore applying measures nationally would ensure all vulnerable
sites are covered, and would make it easier to cooperate these
measures with other Defra measures to reduce diffuse pollution
sources.
8. Currently many of the UK's salmon and
trout rivers are outside designated NVZs. We feel that applying
the Action Programme throughout England can only benefit fisheries,
in that it will undoubtedly bring nitrate levels down in watercourses
and lakes. We believe this measure will also have wider benefits;
for example improving slurry storage will reduce the frequency
of accidental pollution incidents. This can only be beneficial
to the ecology of rivers and lakes in the future, and in meeting
the objectives set out in the Water Framework Directive (WFD).
9. Regulations, however important, that
cannot be enforced will never achieve the required results, with
failure to observe them playing a lesser role.
10. What should be the timetable for introducing
any changes in the way the Nitrates Directive is implemented?
The S&TA strongly supports bringing the
regulations into force on the suggested date of April 2008, as
measures such as fertiliser and manure spreading can be adopted
straightaway. Obviously, farmers will require more time for measures,
such as constructing slurry tanks. However, we feel this timetable
is currently too vague and, if there is to be some temporary relaxation,
the conditions under which they can be allowed must be rigidly
defined.
11. What are the costs and benefits of Defra's
individual key proposals for the revised Action Programme, namely:
whole farm manure nitrogen loading limit, closed period (organic
manures), manure storage, closed period (manufactured nitrogen
fertilizers), crop nitrogen requirement limit, spreading locations,
spreading techniques, record keeping and cover crops. Should any
of these be abandoned or modified?
The S&TA welcomes the strengthening of the
Action Programme, and believes they represent the minimum requirements
needed. We strongly support the need to reduce fertiliser and
manure usage on farms, and improve slurry storage capacities.
12. We also support the inclusion of cover
crops to minimise bare sediment exposed during the winter period.
We feel this would not only help reduce excess nutrients, such
as nitrates and phosphates, and agri-chemical contaminants, such
as sheep dips, reaching the river systems, but would also reduce
sedimentation of watercourses in heavy rainfall events. Excess
sediment in rivers causes major problems to fish populations,
particularly salmonids, where smothering of spawning gravels and
oxygen deprivation of eggs and fry, result in reduced reproductive
success. We feel guidance into cover crop management would be
required, though, to ensure no other net negative environmental
impacts would occur; for instance, during the destruction of the
cover crops.
13. What advice and support will farmers need
from Defra to implement a revised Action Programme?
We feel farmers will need clear, comprehensive,
written advice, explaining what they will be required to do, how
they can achieve it, the penalties of non-compliance, and the
benefits of following the guidelines. This support should also
be backed up with technical visits.
14. How can Defra encourage greater adoption
of anaerobic digestion as a way of managing manure?
The S&TA supports the idea of anaerobic
digestion and feels it could be an effective way of managing manures,
as long as the scale of the operation is large enough to be viable
and the location of any plant is close enough to the supply of
manure, for the operation to meet sustainability principles.
15. We feel the main barriers in its uptake
are financial rather than technical. We therefore believe funding
or incentives schemes would be required to facilitate greater
uptake. Educating the farmers of the process of anaerobic digestion
and its benefits are also an important step to gain support for
the initiative.
16. How the proposed new Nitrates Action Programme
is affecting those with existing Entry Level Stewardship agreements
in existing Nitrate Vulnerable Zones.
N/A
January 2008
| 
