Memorandum submitted by the Association
of Chief Estates Surveyors and Property Managers in Local Government,
Rural Practice Branch
EXECUTIVE SUMMARY
1.1 The County Farms Service is provided
by 62 Local Authorities; 31 County Councils, 17 Unitary Authorities
and 14 Welsh Authorities.
In total we manage 117,705 hectares (290,850
acres) let as 2,699 equipped holdings, with a further 1,095 bare
land lettings.
In 2006-07 we let 37 holdings to new tenants
to the industry. A total of 155 new tenancies were signed in the
year.
1.2 25 of the 62 Authorities are specifically
dairy or dairy/stock rearing estates. The typical dairy holding
is an intensive unit carrying one cow for every productive acre.
This has been driven by the economics of the past 10 years and
by the nature of the tenants selected by the Services, who have
been by nature progressive, wishing to build stock numbers and
thereby be in a position to move to a new larger holding whenever
the opportunity presented itself.
1.3 Capital investment on all of the 62
Estates totalled £9.8 million in 2006-07, but the five year
average of investment is only £7.4 million. Investment has
been targeted at improved modern facility for modern tenants to
produce to modern standards; this includes pollution management
on intensive dairy holdings.
1.4 This response is a composite response
provided from all ACES Rural Branch members. The Committee should
know that many Authorities face difficult decisions over their
continued support of their County Farms Services. Additional capital
investment requirements for slurry storage, as required under
this proposal, will put further pressure on the Service and potentially
call in to question the continued political support for these
services.
2. Has Defra's implementation of the 1991
Directive been adequate?
No comment
3. 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?
No comment
4. Defra says that the area designated as
Nitrate Vulnerable Zones needs to increase from 55% to 70% of
England: is it right?
We ask what is the scientific basis for this
increase. If there is a sound scientific basis for the increase
then undoubtedly some form of regulation should be implemented.
It is our suggestion that the Catchment Sensitive Farming Initiative
should be broadened to target specific rivers or catchments with
high nitrate loadings rather than blanket regulation.
5. Whether the proposed Nitrates Action Programme
measures should apply throughout the whole of England, rather
than only on land designated as Nitrate Vulnerable Zones
Any measure introduced should be done with the
backdrop of sound scientific study rather than the perceived notion
that 100% is best to give the "level playing field".
6. What should be the timetable for introducing
any changes in the way the Nitrates Directive is implemented?
Due to the size and diversity of Statutory Smallholding
Estates it would not be reasonable or feasible to implement all
the changes within 24 months. Therefore from a practical asset
management view this should be extended to at least 48 months.
7. What are the costs and benefits of Defra's
individual key proposals for the revised Action Programme, namely:
— Whole farm manure nitrogen
loading limit;
This needs to be linked to scientific evidence.
— Closed period (organic manures):
This needs to be linked to specific growing periods
of the soils involved. There are areas such as Cornwall where
they can achieve 12 month growing seasons and would therefore
require the ability to spread throughout.
Needs to be linked to the growing season—the
previous NVZ system where each farm prepared its own management
plan to reflect the specific circumstances of the holdings climate,
topography etc is a more appropriate solution than a blanket approach.
This farm specific approach will mean that areas which have an
early growing season can make the best use of it whilst not damaging
the environment.
This is the most contentious area within the
Nitrates Directive for the Statutory Smallholding Estates and
their Managers. As explained in our opening brief many of our
farms are relatively small intensive units already to ensure that
a reasonable livelihood can be made. It is anticipated that where
units have little or no storage currently the cost per farm could
be up to £65,000 per unit. If one places this across the
English Estate as a whole this could represent £8.97 million
capital investment by Councils. This figure only represents farms
entering new NVZ areas not those already in that may need additional
infrastructure.
Various colleagues have done preliminary work
with budget figures returning at up to £4.2 million for a
South West Authority to £1.82 million for a North West Authority.
There is little scope for Landlords to gain a
return on investment and more concerning is that many tenants
would not have the capability of raising such sums of money to
do the work themselves. This would therefore raise the spectre
of County Councils deciding not to support the dairy industry
with NVZ areas and converting farms to mixed farms.
— Closed period (manufactured
nitrogen fertilizers)
This should be based on local conditions with
supporting scientific evidence.
— Crop nitrogen requirement
limit
There appears to be little or no scientific evidence
to back up these limits. If produced and verified then measures
can be adopted to comply with the proposed measures.
This measure is reasonable and was an integral
part of the old management plans which were farm specific.
Whilst the measures seem to be appropriate they
need to be driven by scientific evidence.
This should mirror the existing NVZ systems and
emerging cross compliance updates to ensure uniformity not least
for the regulators but the farmers as well.
Cover crops on over winter stubbles would appear
to lack any form of justification especially if farmers are complying
with their soil management plans with regard to leaching and erosion.
The overall loss of over winter stubbles we believe would be far
greater than the benefit perceived to be gained by placing a cover
crop on them.
— Should any of these be abandoned
or modified?
8. What advice and support farmers will need
from Defra to implement a revised Action Programme?
It is our belief that if the new consultation
is introduced without change, there will be the need for specific
holding by holding guidance. Each farm is different and as such
the guidance will need to be made holding specific.
9. How can Defra encourage greater adoption
of anaerobic digestion as a way of managing manure?
From work carried out by member authorities
the cost of implementing an AD scheme is not beneficial to the
small intensive unit. The added burden in management on the farmer
would not meet the small commercial gain they could achieve by
installing such a system.
10. How the proposed new Nitrates Action Programme
is affecting those with existing Entry Level Stewardship agreements
in existing Nitrate Vulnerable Zones
No specific knowledge.
January 2008
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