Water UK

Catchment-sensitive farming

13/09/04

1) Introduction

Water UK is the representative body of the water industry in the UK. Diffuse pollution has a major impact on raw water supplies used for public water supply. Similarly, diffuse sources of pollution, particularly nutrients drive the designation of sensitive waters under the UWWTD, which can lead to unsustainable increases in wastewater treatment investment. We believe improved, effective controls on diffuse pollution are essential in order to develop sustainable solutions to water quality problems. Therefore we welcome the opportunity to reply to this consultation.

2) Key points

Water UK welcomes this consultation. We recognise that Defra has committed a large amount of staff time and has focussed considerable expertise in addressing the catchment-sensitive farming issue. The options set out in the consultation provide a sound basis for policy development.

Addressing diffuse pollution is essential to meet the statutory requirements of the Water Framework Directive, to reduce the chronic pollution of the raw water used for public supply and to meet the Government’s own targets on HAP and BAP.

Unless this issue is addressed the UK will face infraction proceedings under the WFD water supply company treatment costs will continue to rise dramatically pushing up customers’ bills and increasing our energy use requirements.

Many of our most important natural habitats will remain in unfavourable state and PSA targets for SSSIs will be missed.

Given the importance of the issue, we would expect the Government to commit resources to catchment-sensitive farming. As a minimum we would like to see catchment officers appointed to advise farmers and others on integrated catchment management and to help reduce diffuse pollution levels. Seed money to fund officers must be provided directly by Government to ensure their role as an independent facilitator. Unless this core funding is in place, there is a concern that all the approaches outlined in the consultation will fail to deliver fully.

3) Detailed points

Q1 Do you agree that there is a significant problem with agricultural emissions to water that will require action beyond current and planned policies?

Yes there is a significant problem.

The water industry in the UK has to treat raw waters to remove nitrates and pesticides before putting water into public supply. All water companies have extensive datasets showing pollution levels at abstraction points. The level of treatment required to meet the Drinking Water Directive requirements is increasing annually, both groundwater and surface water is contaminated, the issue is national. The industry has to build new treatment plants and in some areas it is becoming difficult to meet demand because of water pollution from agriculture. The evidence of agricultural contamination is visible at a large number of water treatment plants across the UK. There is no question that the majority of the contamination is from agriculture as individual pesticides can be traced back to agricultural production and nitrate peaks coincide with fertiliser applications.

Current policies have not halted the upward trends in nitrate and pesticide pollution. It is unlikely that planned policies will halt the trends and they will certainly not reverse the trends.

We currently have 6 major estuaries in England, which have been detailed in Reasoned Opinion from the Commission, in whose opinion these waters should have been designated as sensitive under the terms of the UWWTD. By working with the EA and Defra, it has been demonstrated that the majority of the nutrients arriving at these estuaries are from diffuse sources. Unless such sources are effectively dealt with, it seems inevitable that sooner or later such sorts of designations will be made at least at some of these sites. These will drive huge investment programs in the water industry which we have already established from the work completed by Yorkshire water would cause more environmental harm than good. It remains essential therefore that effective and efficient measures are put in place to reduce significantly diffuse pollution to our waters, by implementing strategies, policies and practical solutions at the sources of such pollution.

Q2 Which aspects of the evidence base presented in Section 1 do you think require extra investigation as a basis for policy development?

The evidence base is sufficient for action to be taken to address the problem. Resources should be targeted into developing catchment-based solutions. Extra investigations should focus on the impact of mitigation actions not on further identification of the problem. However outwith the Catchment-Sensitive Farming work programme, the UK should be investing more in hydrology, hydrogeology and hydroecology, there is a lack of understanding of physical processes within catchments and more resources should be invested in the basic science, this is an issue for the research councils.

Q3 Do you think that farmers have sufficient access to the information and skills required to respond to the causes and effects of agricultural emissions to water and to develop and implement solutions?

No. There is a lack of site-specific information, both on the problem and the solutions. It is essential that farmers be given information on the problem in their catchment and the actions they can take to address the problem. General statements and policy instruments at a national level will not have the required impact on-farm as farmers will still be unsure as to what action they should take.

Government must provide seed money for catchment officers to provide independent advice and act as facilitators at the catchment scale. The catchment officers could also co-ordinate collaboration between farmers and other stakeholders. This is the case in France where the Ferti-meiux programme brings together water companies, farmers, industry, NGOs and local authorities and agricultural colleges.

Q4 Do you agree that we will need to address farm inputs, land management and land use? Should any farm practices be priorities for implementation at a national or targeted level?

Yes. Farm inputs, land management and land use should all be addressed. There is general agreement on the type of practices that should be followed, it is the issue of communication should be the priority. It is essential that there are clear delivery structures that enable farmers to understand what are the problems in their local catchment and how action on their farm could reduce the problem. The experience of the Voluntary Initiative project 10 indicates that this requires local delivery of expert advice. This can be done through agronomists, champion farmers and other stakeholders, but is requires co-ordination, which again can be provided by a catchment officer.

Q5 Do you agree with the proposal to take early action to promote catchment-sensitive farming to:

a) Deliver pressing water quality and conservation targets
b) Help farmers to prepare for forthcoming regulatory requirements
c) Pilot action and improve our knowledge of the action required

Yes. The problems are chronic and require immediate action. Many organisations are already taking action and there are a large number of projects already underway in a number of catchments (see www.uk-adapt.org.uk for an extensive list). What the current initiatives lack is co-ordination and inter-comparison, there is not enough learning between projects, again a network of catchment officers could deliver this.

Q6 Do you agree with the proposal to begin any targeted action in priority conservation catchments?

Water UK has been involved in the discussions of targeting and we would like to see priority action targeted at catchments with both conservation and water quality issues.

Q7 We have characterised four broad approaches on which we are seeking views, but these are not mutually exclusive and indeed we expect that the optimum approach will probably contain elements of several of them. Based on the options set out in section 4:

A) What is your assessment of each of the four options for possible approaches and the individual policy instruments within them? How could each be improved?

Option 1. This is a dangerous approach; it is unlikely that existing policies alone will solve the problem. This approach is likely to lead to infraction proceedings and hurried late regulation, which past experience shows is not cost-effective.

Option 2. A wholly regulatory approach is unlikely to succeed, as it will not have the support of farmers. However it is clear that there is a role for the introduction of some early regulation to strengthen the existing Environment Agency powers on pollution to cover diffuse pollution.

Option 3. This is the most attractive approach. There are a number of good examples of co-operative agreements and voluntary action in mainland Europe.

Water UK’s involvement in the Voluntary Initiative on pesticides demonstrates that it is possible to make progress through voluntary action, however it also demonstrates that voluntary action requires seed funding and requires a co-ordinator to facilitate dialogue, this is a role of a catchment officer

Voluntary action works best when it is underpinned with financial support, this can often be small amounts of money and could come from sources other than central Government, NGOs, water companies, RDAs and other bodies are already providing support and assistance to farmers groups to help them reduce diffuse pollution. However the best way to leverage support from third parties is through a catchment officer structure.

It is essential that there is a sound science base to underpin voluntary action, this can be provided through the a number of organisations including water companies, however it has to be delivered to farmers through a trusted medium, such as the NFU, ADAS, agronomists, other farmers, or the statutory levy bodies. Again a catchment officer would be able to co-ordinate this information delivery.

It is also worth noting that once voluntary action is accepted as the norm by the farming community it often gets adopted by the assurance schemes, so there is a degree of self-regulation.

The targeted use of CAP money will also have significant benefits in reducing diffuse pollution and we appreciate the UK Government’s achievements in reforming the CAP agenda to deliver environmental protection. However, whilst re-direction of CAP money will have significant benefits will not alone be sufficient to address the diffuse pollution problem.

Option 4. Water UK is opposed to the use of economic instruments in this case. Our concerns relate to the complexity of the schemes, their administrative cost and their potential perverse impacts. Economic instruments are based on the assumption that farmers are using excessive amounts of nutrients and pesticides. If this is the case a tax will have little impact unless accompanied by advice on how to reduce usage. We are also concerned that economic instruments will reduce farm incomes and this often leads to increased pollution incidents as farmers cut costs. Finally we are concerned at the potential difficulties in implementing economic instruments in Scotland on what is otherwise a devolved issue.

B) Do you think that a combination of policy instruments would be the best approach to promoting catchment-sensitive farming?

Yes a combined approach is preferred.

C) How would you rank the combined approaches in section 4.69 in terms of effectiveness and acceptability? Please explain why you would prefer each approach to less favoured alternatives.
D) What would be the optimum package of policy instruments for promoting catchment-sensitive farming?

The optimum package of measures is a supportive package with seed funding for catchment officers accompanied by some early regulation giving the Environment Agency powers to require on-farm action to address diffuse pollution (similar to statutory nuisance powers or works notices in Scotland). Water UK and the water industry would provide support for this approach by working with farmers and others to promote best practice.

Q8 What would you expect the overall distributional impacts of the possible approaches to be including:

A) Costs; in particular in relation to farm incomes, competitiveness, agricultural suppliers, the food industry, consumers and others?
B) Benefits; in particular in relation to environmental effectiveness of the approaches?

We agree with the preliminary assessments made in the consultation. It is difficult to assess costs and benefits without knowing the detail of the approaches. However, we believe the supportive approach combined with limited new regulation and underpinned with Government seed money for catchment officers is the most cost effective approach. This will leverage external third party funds (mainly in kind) and will promote voluntary action on low and no-cost measures by farmers.

Q9 Do you agree with the approach we are taking to develop indicators to assess the effectiveness of policies to reduce water pollution from diffuse agricultural sources?

In general we agree with the approach to measuring effectiveness. However, a clear indicator is the level of contamination at drinking water abstraction works. This relates directly to Article 7 of the Water Framework Directive and has a direct bearing on water customer’s bills. Until we see a reversal of the upward trends in
contamination the problem is not being tackled and until we are compliant with the Drinking Water Directive standards at the abstraction point there is still a problem facing the water industry.

4) Conclusions

Water UK welcomes this consultation and the detailed work programme on catchment-sensitive farming.

We believe that it is essential that action is taken on this issue as soon as possible.

Our favoured option is the supportive approach coupled with some early regulation and underpinned by catchment officers with initial seed funding from Government.

We are opposed to the use of economic instruments as they are unlikely to provide the most cost-effective approach to solving the problem.

We would like to see action focussed on protecting drinking water sources as well as environmental protection.

Water UK and its members are already working with a number of organisations such as farmers groups and NGOs to promote catchment sensitive farming. We would be willing to provide support for Government funded independent catchment officers.

Ends

For more information please contact
Jacob Tompkins, Policy Development Adviser
020 7344 1817