Memorandum submitted by the National Pig
Association
The National Pig Association (NPA) is the representative
trade association for British commercial pig producers and also
represents the pig interests of National Farmers' Union members.
Thank you for the opportunity to provide evidence to your enquiry.
EXECUTIVE SUMMARY
The pig industry is concerned about nitrate
levels and is keen to assist Defra in meeting its objectives.
The current Action programme (AP) meets the objectives of the
Directive and we are confident our sector's contribution through
existing measures and changes of practise will help deliver much
of what is proposed.
The industry remains unconvinced by the science
put forward to justify the enlargement of the NVZ area from 55%
of the country to 70%. There are a large number of contradictory
findings in terms of surface and ground water nitrate levels,
the pig industry's contribution has decreased significantly partly
due to the sizeable reduction in the national herd, and also through
improved feeding technology.
The more onerous requirements are being proposed
on the back of increases in nitrate levels due to farming practises
over 20 years ago. The systems that are now in place will lead
to further nitrate reduction when it has had sufficient time to
feed through the aquifers.
The Defra consultation document estimates that
the changes to closed periods will only result in a 0.5-1.0% reduction
in nitrate levels, very small in comparison to the costs (estimated
as at least £40 million for the pig sector) and burdens being
imposed on a fragile industry without the ability to recover costs.
A timetable for implementation of the proposed
changes to the AP needs to take account of other pressures on
the industry, such as available capital and planning consent.
Producers should have two years to draw up an implementation plan
and five years to complete the changes.
Slurry storage should be calculated on a risk
basis relating to each farm and the land available to them for
spreading, not exceeding a requirement for six months.
The use of cover crops is likely to result in
pollution swapping, this proposal should be removed.
We ask Defra to encourage the uptake of best
practise by providing similar levels of capital support to that
received by other countries, such as Northern Ireland that received
60% grants to meet slurry storage requirements and in Holland
where government assisted in the investment in improved slurry
spreading techniques.
SUPPORTING INFORMATION
The National Pig Association (NPA) is the representative
trade association for British commercial pig producers and also
represents the pig interests of National Farmers' Union members.
We offer a number of comments which we hope
will be useful in your enquiry. The pig industry is committed
to reducing nitrate levels and is keen to assist Defra in meeting
its objectives. We are confident our sector's contribution through
existing measures and changes of practise will help deliver much
of what is proposed. We have a number of concerns about the impact
of the revised Action Programme (AP) on our industry.
1. HAS DEFRA'S
IMPLEMENTATION OF
THE 1991 DIRECTIVE
BEEN ADEQUATE?
Defra's consultation presented evidence of a
steady reduction in surface water nitrate levels, which suggests
the current AP is delivering the right results. Groundwater results
cannot show quick enough changes in nitrate levels to be used
as a reliable indicator in the short timescale of the AP, unlike
surface water levels that react much quicker.
The NVZ's designated in 2002 have been measured
against an insufficient period of monitoring data for Defra to
be confident in making the claim that more onerous measures are
needed. The following graph seeks to underline this point as our
industry has contracted sharply in the same period, which will
have significantly reduced our sector's contribution to Nitrate
levels.
Source: Defra June Census.
Improved animal genetics and feed rations has
resulted in better utilisation by the animal and less N being
fed to the pig in the first place.
Producers have found the current AP useful in
concentrating their focus on improving the utilisation of their
nutrients, however they find the new proposals demoralising as
being in many cases unachievable.
2. THE INCREASE
IN DESIGNATED
AREA
The Action Programme should not be extended
across the whole of England. NVZ designation should follow scientific
analysis and only be introduced where the nitrate level of surface
or ground water is above or close to the 50mg/l limit although
we believe this limit should be higher.
The NPA has requested that Defra review the
nitrate level as there is no scientific justification from an
environmental or human/animal health perspective for the level
to be set at 50mg/l. This was an arbitrary figure chosen by the
EU Commission, the impact of which has enormous cost implications
to English livestock industries.
3. WHAT SHOULD
BE THE
TIMETABLE FOR
IMPLEMENTING CHANGES
TO THE
WAY THE
NITRATES DIRECTIVE
IS IMPLEMENTED?
A realistic timetable needs to take into account
a number of practical industry issues that will impact on the
speed with which the new proposals could be implemented, such
as:
— Production costs have increased
by 35% due to the doubling of feed prices last year, so capital
available for investment is at an all time low.
— Achieving planning consent is
increasingly costly and time consuming.
— The manufacturing industry in
the UK is unlikely to be able to meet the sudden increase in demand
for slurry stores across the livestock industry.
— Tenancy issues should be considered
in terms of requiring a landlord's permission, or being a viable
option if operating under a short term agreement.
— The requirement for reduced
ammonia levels under the Habitats Directive could prevent the
implementation of some proposals.
Producers should be required to provide a plan
of their improvements within two years, with the necessary work
completed after five years.
4. THE COSTS
AND BENEFITS
OF DEFRA'S
KEY PROPOSALS
FOR THE
REVISED ACTION
PLAN
The pig industry has calculated the effect of
some of these key proposals to the sector:
— An additional annual cost of
at least £1.5 million/year for slurry spreading by the requirement
for Spring applications (requires specialised equipment).
— £36 million for increasing
slurry storage.
— £4 million for increasing
storage for Farm Yard Manure.[13]
— Loss of the Agricultural Buildings
Allowance has resulted in our members facing increased tax burdens
this year and a disincentive to make investment.
The RIA presented in Defra's consultation is
confusing, poorly presented and fails to recognise how components
of the AP interact and impact on costs. The costs detailed above
simply cannot be met in the current financial environment within
the pig industry and will serve only to export a significant proportion
of production, where we have no control over how it has been produced.
5. MANURE STORAGE
Minimum slurry and manure storage requirements
should not be specified. Storage should be calculated on a risk
basis relating to each farm and the land available to them for
spreading, not exceeding a requirement for six months.
6. CLOSED PERIODS
The NPA challenges the principle of closed periods
being based so strictly on soil type and rainfall. This approach
does not take into account UK rainfall patterns or the variety
in topography and local climate. Spreading should be permitted
based on field risk assessment including soil type, slope and
how the field is being used.
7. COVER CROPS
The use of cover crops is likely to result in
pollution swapping. The benefit that might be gained through prevention
of N leaching needs to be off set against the use of fossil fuel
intensive field operations and use of chemicals, and a risk of
soil structural damage. This proposal should be removed.
8. SUPPORT MEASURES
To assist industry in meeting its environmental
obligations under the Nitrates Directive, the pig industry asks
to receive similar levels of capital support to other countries,
such as Northern Ireland that received 60% grants to meet slurry
storage requirements and in Holland where government assisted
in the investment in improved slurry spreading techniques.
The pig industry has detailed its vision in
the Pig Environment Partnership, where industry, government and
other agencies responsible for the environment can work more closely
together to remove the need for such restrictive legislative controls
on farm and work on a lighter touch risk based approach that delivers
an environmentally and economically sustainable industry.
January 2008
13 Breakdown of cost calculations in attached annex
spreadsheet. Back
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