VEGA responds to a Defra consultation on diffuse sources of water pollution from agriculture
VEGA's response to the Defra consultation on diffuse sources of water pollution from agriculture follows:
Whilst we do not feel informed sufficiently to make detailed comments on the proposals and three policy options, we would like to make the following general points:
1. The targets for reduction of P, N and sediment in watercourses provide useful motivation towards implementation of better agricultural practices. However, these targets should not be an end in themselves. The more significant sources of effluent should be targeted, but other sources should not be ignored. Likewise, all watercourses must be protected, not just those that are worse affected or those of special interest.
2. Many of the Mitigation Measures listed in Annex B would produce significant environmental benefits besides the targeted reductions in P, N and sediment (eg reduction in soil erosion and methane emissions). In the cost/benefit analysis, the benefits accruing to implementation of the various policy options could therefore be much greater than those simply arising from the reduction in P, N and sediment.
3. We believe that there must be a component of advice for farmers included in the policy package chosen in order to maximise its effectiveness. It is not clear, however, what the advantages and disadvantages would be of including water options in the Environmental Stewardship Scheme.
4. Just as you have pointed out that addressing water pollution should address the causes in preference to ameliorating the effects, we comment that pollution of watercourses is as much a product of particular farming systems as it is a product of specific practices within a farming system. Intensive livestock farming is well known for production of large quantities of effluents which cannot easily be handled or disposed of safely. High input / highly mechanised arable agriculture can also be a major contributor to pollution – though we note that much of the output of arable farming goes to support intensive livestock farming. We therefore believe that policy measures should address and target specific farming systems in preference to tackling the problem further ‘downstream’.
5. There should be incentives and encouragement for good practice as well as for farming systems that are less polluting. Organic and plant-based systems of agriculture (eg using green manures and composts to retain fertility and improve soil structure) are clearly less polluting than intensive livestock farming or high NPK-input crop growing and we believe that ‘low input, low pollution’ systems must be supported and encouraged.
6. Monitoring is crucial to effective implementation of these proposals and to the targets being achieved. Although we agree that monitoring should be targeted at areas where maximum reductions in water pollution can be achieved, this should not be a reason to neglect more extensive monitoring.