Memorandum submitted by the Meat and Livestock
Commission
EXECUTIVE SUMMARY
1. The existing Action Programme (AP) meets
the objectives of the Directive, the proposed changes are over
prescriptive, disproportionate and would be detrimental to the
long-term sustainability of the livestock sector.
2. Proposed revisions would impose considerable
burdens on the livestock and meat industry resulting in further
contraction and loss of competitiveness.
3. For the polluter pays principle to be
adopted, Government and its advisers must share responsibility
for past actions, some poor water quality is a consequence of
a period when production was encouraged and environmental science
less developed.
4. The case for a revised AP is weak; water
quality data show sustained improvements towards the objectives
being met. N excretion has declined because of falling livestock
numbers and improved feeding technology. There will be a time
lag for the benefits to show but this is not taken into account
in monitoring data.
5. Designated areas must only be extended
where there is a clear case, full or partial de-designation should
be considered for areas already achieving water quality objectives.
6. For water quality objectives to be met
before the next four-year review, key changes to the AP must be
implemented quickly, but phased to allow investment and improvements
to be made with a set time to prepare proposals and seek permissions
and a further period to complete.
7. A risk-based approach is needed for manure
storage requirements and closed periods for an overall better
environmental outcome.
8. The Cover Crop proposals should be dropped
as the drawbacks outweigh any benefits.
9. Support measures to demonstrate and encourage
uptake of best practice, and financial incentives are needed for
desired outcomes to be delivered without irreversibly damaging
the rural economy and meat industries.
SUPPORTING INFORMATION
10. The MLC is an executive Non Departmental
Public Body set up under the Agriculture Act 1967. Its remit is
to work with the British meat and livestock industry (cattle,
sheep and pigs) to improve its efficiency and competitive position,
and to maintain and stimulate markets for red meat at home and
British meat abroad, with due regard for the consumer. Its activities
are funded through the collection of levies on sheep, pigs and
cattle slaughtered for human consumption or exported live.
11. We note the remit of your enquiry and
offer our comments in response accordingly. Our work within the
livestock sector recognises the need for reducing the environmental
impact of livestock production whilst developing sustainable and
internationally competitive livestock industries. We are concerned
about the impact of these revised regulations on the livestock
sector.
HAS DEFRA'S
IMPLEMENTATION OF
THE 1991 DIRECTIVE
BEEN ADEQUATE?
12. The targeted AP implementation has been
adequate, based on the evidence presented in the consultation
indicating general decline in surface water nitrate concentrations.
13. Surface water shows a faster response
than groundwater to declining nitrate loss from agricultural land
providing a better indicator of trends attributable to the AP.
Data presented for the period 1999 to 2005 is unlikely to demonstrate
clear responses to the 2002 AP as we highlighted during discussions
with Defra Water Quality Division. Results presented, do not distinguish
between 1998 designated zones (8% of England), 2002 designated
zones (55% of England) or undesignated catchments.
14. For 2002 designated NVZ's, winter 2003-04
was the first full nitrate loss season. With time lag, two years
monitoring data is insufficient to conclude that more stringent
measures are needed. During this period livestock numbers and
fertiliser use have fallen dramatically, weakening the case presented.
Source: Defra June Census.
15. Livestock feeding technology and genetics
are improving; less N is being fed with better utilisation, a
gradual process not identified within the water quality data.
16. We are unable to distinguish between
economic and demographic changes in farming practice and implementation
of the AP to gauge how effective it has been in reducing nitrate
pollution. Knowledge and understanding of farmers regarding use
of N fertiliser and manures is improving, in part due to the AP
focusing on nitrate utilisation.
17. Regulations are only effective if those
implementing them understand the subject; it is preferable to
achieve goals through knowledge transfer and demonstration in
preference to tighter and inflexible legislation.
EXTENT OF
DESIGNATED AREA
18. Where evidence suggests agriculture
is responsible for failure of water quality objectives we expect
NVZ's to be designated. Where objectives continue to be met, or
agriculture is not the prime cause of any failure, these areas
should not be designated.
19. Catchments where there is evidence that
objectives would still be met if full or partial de-designation
took place, this should be implemented.
20. We would still like to see undesignated
or partially designated areas being treated equally for knowledge
transfer or fiscal support as NVZ's. All land managers must be
encouraged to strive for improvement and deliver environmental
benefits, helping demonstrate that Defra is committed to ensuring
objectives are met across the whole of England.
WHAT SHOULD
BE THE
TIMETABLE FOR
INTRODUCING ANY
CHANGES IN
THE WAY
THAT THE
NITRATES DIRECTIVE
IS IMPLEMENTED?
21. For AP changes to deliver positive results
before the next four-year review key components need to be introduced
quickly to allow for time lags.
22. The livestock sector is not currently
able to finance all of the necessary investment on account of
its weak economic position. The following points should be recognised:
— Capital in many cases is not
currently available.
— Long-term confidence is low.
— Tenants require landlords consent
for investment.
— Farmers/landlords with short-term
tenancies or other agreements will be unwilling or unable to invest.
— Assessing options, preparing
scheme details, planning and consents are risky and take time,
especially where opposition is met or impact assessments are needed.
— Reduced critical levels for
ammonia under the Habitats Directive will result in some proposals
being challenged, refused or requiring mitigation measures at
additional costs.
— Slurry store construction is
a specialist activity; the construction industry does not have
capacity to take on additional workload. This will increase costs
and may result in poor standards of workmanship increasing the
risk of structural failure and pollution.
— Competition from other projects
is increasing construction costs and causing localised supply
difficulties.
23. To avoid farmers delaying implementation,
they should be required to prepare a scheduled programme of improvements
and have applied for all necessary authorisations and approvals
within 24 months and completed the works within four years.
COSTS AND
BENEFITS OF
DEFRA'S
INDIVIDUAL KEY
PROPOSALS FOR
THE REVISED
ACTION PROGRAMME
24. Administrative burdens and costs will
increase for farmers. Circumstances surrounding each farm are
unique, for example in many cases administration is not costed
as it is carried out by the farmer or family members.
25. The interaction between various AP components
on costs are not recognised within the RIA, and the write-down
period for capital expenditure is longer than normal for this
industry, this is seriously flawed.
26. Unless financial returns improve farmers
will continue to exit the sector with loss of critical mass in
the supplier, service and meat industries. Meat processors will
not be able to satisfy demand for home produced products forcing
them to import. Ability to support home prices by exporting products
with low UK value will be impaired, as was demonstrated during
the recent export ban.
27. For the polluter pays principle to be
adopted, Government and its advisers must share responsibility
for past actions, some poor groundwater quality is a consequence
of a period when production was encouraged and environmental science
less developed.
STORAGE REQUIREMENT
28. Specified minimum storage requirements
for manures and slurries are not required. Manure Management Plans,
as Defra has promoted in the past, can determine the needs of
each unique farm through a risk-based approach.
CLOSED PERIODS
29. Fail to recognise local factors influencing
crop growth and N uptake. Flexibility at the start and end of
closed period, with a reduced interim application limit would
permit a risk-based approach. This will reduce water and air pollution
risks when restrictions are lifted, and allow greater crop N uptake
as plant nutrient requirements and application can be better matched.
COVER CROPS
30. The proposed measures should be removed
as they will not be effective in all instances and can, as mentioned
in the consultation impair N availability to following crops.
Fuel use and other resources would increase, and make some crops
unviable.
31. The balance of environmental impacts
has not been adequately considered in the preparation of the revised
AP with regards to this and other revisions.
SUPPORT MEASURES
32. A sustained reduction in water nitrate
levels requires farmers and land managers to understand N management
including adoption of modern animal feeding technology.
33. Some farmers are very knowledgeable
and have invested in equipment and tools to improve N use and
cost savings. There is scope for all farmers to achieve higher
standards. Extension of the ECSFDI and greater co-operation between
Defra, its agencies and the levy bodies must be encouraged to
deliver this objective.
34. Demonstrations of good practice including
making spreading equipment available to farmers will help break
down resistance to change, and convince doubters that they can
make the necessary changes to deliver the desired outcomes.
35. Financial support is required to enable
farmers to make the necessary capital investments; this includes
grants and restoration of taxation incentives.
36. There needs to be greater partnership
and dialogue between Defra, Environment Agency, Regional Development
Agencies, industry and other stakeholders to develop a culture
of co-responsibility and devise solutions that mean more comprehensive
and tight controls are not needed in the future and to identify
where those in place can be relaxed. The BPEX Pig Environment
Partnership is such an example.
January 2008
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