Environment, Food and Rural Affairs CommitteeWritten evidence submitted by National Farmers’ Union

Introduction

1. The NFU represents 55,000 farm businesses in England and Wales involving an estimated 155,000 farmers, managers and partners in the business. In addition, we have 55,000 countryside members with an interest in farming and the country.

2. The NFU welcomes the opportunity to respond to the Environment, Food and Rural Affairs Committee’s call for evidence for their Water White Paper, inquiry as the quality and availability of water has major consequences for food production. The NFU and its members recognise the need for a more sustainable water management regime to help secure and improve the quality and quantity of food produced in England and Wales.

3. The Committee has asked for comments on six specific issues:

4. Whether the White Paper’s aims are supported and the likelihood of these objectives being effectively fulfilled by the approaches it proposes

The NFU welcomes the Water White Paper as an opportunity to identify appropriate measures consistent with a more sustainable water management regime. However, we have a number of concerns (outlined below) which we believe could risk delivery of successful sustainable water management in England and Wales.

5. Does the White Paper set out the right principles for customers and the water and sewerage industry for taking forward reform of the market for water supply

While we agree with the principle of building on the strengths of the existing regime, the NFU is concerned that the development of a single market in abstraction licence trading could lead to a haemorrhaging of agricultural water rights. Farmers and growers use less than 1%, of the total amount of abstracted water annually1 but this figure masks some important seasonal and spatial variations in farming’s need for access to water rights. In some areas and in drier seasons agriculture is critically dependent on water for irrigation well in excess of this low proportion (conversely in wet seasons licenced access is rarely taken up). In terms of number of licence holders, agriculture holds a disproportionately large number: approximately 62%,2 of the 21, 500 water abstraction licences in England and Wales. Since 2001 all new licences have had an expiry date. Approximately 21% of licences in England and Wales now have time limits.3 The NFU five year water survey showed that of those respondents who had water abstraction licences, approximately 50% of their licences are now time limited. We understand from the Environment Agency, that this is a significantly higher proportion than for other sectors. This demonstrates not only that there is significantly more interaction between agriculture and the abstraction licensing regime than there is in other sectors, but that water rights for agriculture could already be less secure than the non-time limited licences held by other much larger users of abstracted water eg the energy and public water supply sectors. We are therefore concerned that the market, as proposed, could lead to a “David and Goliath” like struggle for water rights in the future. Agriculture, even for irrigation purposes, would be unable to afford to compete in the same market for water access when in competition with public water supply.

6. Are the proposals to protect and enhance water resources, for example on abstraction regime reform likely to be fully effective?

The NFU would like the Committee to acknowledge the substantial improvements on water resources being made by farmers and growers. The NFU’s five year Water Survey (launched in November 2011) showed:

All farming sectors had made improvements with the horticultural sector increasing their water efficiency the most in the last five years.

57% of the horticultural survey participants intend to continue increasing their efficiency over the next five years.

Cash flow was the largest barrier to increasing water efficiency.

7. We recognise the need for the long term reform of the abstraction regime, and that this could provide opportunities for farmers and growers eg through the exchange of water rights on a seasonal basis. We also understand that costs of water (in public water supply) are also driven by pollution control whether for Drinking Water, Bathing Water or WFD purposes, however, the implication that water costs for most people and businesses are set to increase substantially, we find little comfort in, particularly as the increased costs, both in the rates of increase and amounts, are likely in future to be greater in the Anglian and the south-east regions where supply is short and demand is high. These are areas of significant agricultural production and we are particularly concerned, as stated earlier, that developing a single market for abstraction licences and encouraging farmers and growers to sell their abstraction licences when they are not growing a crop that needs irrigating could lead to a gradual loss of abstraction licences for the farming sector.

8. For the abstraction regime reform proposals to be fully effective, the NFU believes the governance framework needs to ensure:

A robust peer-reviewed scientific evidence base underpins policy development.

Continued and secure allocation of water rights for food production in England and Wales.

Safeguards ensure against potential haemorrhaging of agriculture and horticulture water rights to larger abstractors.

9. How best can the White Papers aims to promote water efficiency and the use of sustainable drainage be implemented

The NFU’s five year water survey Water Survey showed that most farmers (over two-thirds) use small volumes (under 20 m3 per day) of mains water to supply their needs and saw no barriers to efficiency. However for those using larger quantities, cash flow was seen by respondents as being the largest barrier to increasing water efficiency. The NFU believe water efficiently and the use of sustainable drainage could best be promoted by measures that:

Encourage investment in the agriculture and horticulture water infrastructure eg increasing reservoir storage, more efficient irrigation systems (such as drip and computerised irrigation systems) and more drought resistant and saline tolerant crops.

Provision of relevant, timely, robust, advice, information and communication in order for farmers and growers to make informed decisions on water efficiency and sustainable drainage.

Addressing the significant gaps in understanding the water availability of different soil types Farmers rarely have access to comparative data on water use by different crop varieties or crops (which would ensure that they group crops and varieties suited to their resources) Recent work by McCain’s shows that some varieties require significantly larger volumes of irrigation water.

Increasing the knowledge base of the implications of using different types of water for agriculture ie recycled, grey, and desalinised water.

10. Do you support the white papers proposals on affordability of water Bills for householders

The NFU are concerned that farmers will be hit by increases in public water supply costs as over two-thirds use mains water (from the NFU’s five year water survey referred to earlier).

11. Does the White paper omit any key issues where further policy action is required to ensure sustainable reliable and cost effective water supplies?

12. In the NFU’s view, further policy action is needed which takes a perspective beyond that simply of water protection and resource use and recognises other environmental and economic dimensions, and of course, the impact on such policies on agricultural productivity and competitiveness.

13. We believe water policy activity must not become driven by risk management of EU compliance requirements rather than the delivery of sustainable reliable and cost effective water supplies. Our concerns are based on previous European level water related policies, such as the Habitats and Water Framework Directive which have tended to result in a risk averse legislative and policy framework in the UK, where productive farmland seems to be considered effectively as a “disposable resource”.

14. The NFU believe further action is required to balance, simplify, and bring consistency between the policy landscapes of biodiversity and the protection natural resources (air, soil and water).

15. We are also cautious about the idea proposed in the White Paper to extrapolate from the 70 catchment scale pilot projects into a national scheme—water is a local issue and a “one size fits all” policy approach will not deliver sustainable water management. In our view, Defra and the Environment Agency need to be committed to improving their understanding about how water moves through different “families” of catchments, as by doing so the catchment approach is more likely to produce value for money outcomes.

January 2012

1 Environment Agency -estimated abstractions from non-tidal surface waters by purpose

2 Defra abstraction statistics http://data.defra.gov.uk/env/iwtb21-ab-purpose-201111.csv

3 Environment Agency – The case for change – current and future water availability

Prepared 4th July 2012