Memorandum submitted by the Country Land
and Business Association
1. The CLA represents the interests of 38,000
land managers and rural businesses who between them manage a variety
of businesses ranging from agriculture, forestry, fishing, tourism
and a wide range of diversified enterprises. These businesses
are at the heart of the rural economy and as well as impacting
on the surrounding environment, as all industries do to some extent,
land managers are good stewards of the land, and create and enhance
the beautiful landscapes and habitats which the public greatly
enjoy visiting. Nitrogen fertilizers—manufactured and organic—are
part of land management businesses, and without which there would
be no livestock farmed landscapes to enjoy.
2. The Nitrates Directive is a deeply flawed
regulation. There is simply no scientific justification for the
arbitrary limit it imposes, and the programme of measures it delivers
is neither rational nor cost effective.
3. The proposed NVZ action programme review
and new NVZ measures do not arise because of any decline in the
quality and health of the UK's water—in contrast the vast
majority of water bodies are, on the Governments own assessment,
improving in quality. Sadly the UK is being driven by European
Officials seeking to secure compliance with an arbitrary target.
3. In fact, the nitrate content of water
bodies varies widely across the country, and in most cases is
in a state of flux, with a general downward trend. However, many
very stable water bodies have relatively high levels of nitrates
owing to historical events (at least some affected by the drive
for food production in WW2) which current management can do little
to alter.
4. Applying a fixed limit to only one of
the wide range of naturally occurring and introduced diffuse pollutants
is not a rational policy, and inevitably imposes disproportionate
costs. A far better approach is set out in the Water Framework
Directive, which is based on an overall objective for the status
of waters, and which has a proportionality test built in.
5. The CLA, having regard for the Haskins
review of regulation has put together its own tests for policy
which can better meet the needs of current and future generations.
We argue that policy should be: based on sound science; proportional;
engage voluntary participation; decentralized; and in order to
lead to sustainable local solutions. The proposals before the
EFRA committee fail on all these grounds.
6. It is absolutely clear that the nitrogen
loading of the countryside is in steady decline, owing to a range
of factors including:
— improvements in plant science and
application, reducing artificial N applications to accurately
meet plant requirements at the optimum time, and the associated
practice of precision farming. This has led to a reduction of
artificial N purchased and applied by 30% in 20 years.
— reductions and concentrations in
the number of livestock into fewer and better equipped holdings
with sophisticated manure management systems. The number of dairy
cows (UK) has fallen by 500,000 to 2 million, radically reducing
the amount of organic N loading in the environment.
— Environmental Stewardship programmes
that help prevent N reaching waters are having a positive effect.
This is being supported by work that is coming out of the Defra
Environmental Observatory.
7. The Environment Agency (EA) monitoring
shows an overall trend—75% of waters have a downward trend
in N loading over five years, which is exactly what would be expected
from the change in farming detailed above.
March 2008
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