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John writes...
Since the Minister for Environment, Energy and Rural Affairs’ ill-timed announcement that Welsh Government plan to introduce Nitrate Vulnerable Zones (NVZs) across the whole of Wales, I have seen and heard numerous misleading statements and reports used as reasoning for the disproportionate approach that is being adopted.
In this blog I want to highlight many of these false and inaccurate claims, correcting, contextualising and clarifying them where necessary.
One pollution incident is one too many
Firstly, I would like to directly address the deliberate misrepresentation by politicians and campaigners of a statement that I, and many other NFU Cymru speakers, have used over recent years: ‘One pollution incident is one too many’. This statement has been a guiding principle for NFU Cymru. It is a signal of leadership and collective responsibility; we could not have been clearer that we absolutely do not condone agricultural pollution and accept the role that we need to play as a Union in tackling this matter. For anyone to quote the union’s use of this statement as some kind of justification for an all-territory approach that is not evidence-led is completely disingenuous. NFU Cymru vehemently rejects the untargeted and unscientific approach being adopted by Welsh Government and by taking this position we are not condoning any form of agricultural pollution that harms our environment. Instead, we want to see regulation that tackles those instances of bad practice, not handicapping the vast majority of farmers whose farming operation has no adverse impact on nearby watercourses.
Agricultural pollution incidents in Wales are rising
Contrary to what some campaigners would have you believe, the number of agricultural pollution incidents in Wales is not rising. The evidence shows a clear downward trend of 28% in the number of agricultural incidents occurring in Wales in the last three years. Many of our catchments have incurred zero incidents of agricultural pollution in the last 10 years. Less than 12% (113) out of 953 Water Framework Directive waterbodies have shown to be failing due to agriculture. It is incredibly frustrating to hear politicians and campaigners continue with this position when it does not match the available evidence.
There are three agricultural pollution incidents per week
A lot of the coverage and interviews you will have seen since the announcement of the regulations seems to be spearhead by the claim that ‘there are three agricultural pollution incidents per week’. Once again, this statement lacks context and does not provide an accurate reflection of the real picture of issues affecting Welsh water courses.
The data that underpins this statistic needs to be understood against the context of Natural Resources Wales’ classification system, which, since 2016, has placed all incidences into high or low impact categories. It’s important to note that low impact incidents are defined as either a) having a minor or minimal impact or effect of the environment, people and/or property or, b) being a substantiated incident with no impact. However, the ‘three agricultural pollution incidents per week’ statement being peddled by government and others accounts for all incidents regardless of their severity, even if there is no impact whatsoever.
A more accurate way for government to portray these statistics would have been to separate those high and low impact incidents. The reality is that, using the Natural Resources Wales data available between 2001 and 2020, the number of high impact incidents – those incidents carrying a major, serious, extensive or significant effect on the environment, people and/or property – average out at one incident of agricultural pollution per fortnight.
While we are consistent in saying that we do not want to see any incidents of agricultural pollution and that an average of 25.75 per year is still too many, it is a far departure from the ‘three agricultural pollution incidents per week’ that the Welsh Government is claiming. The government’s wielding of this inaccurate and emotionally-leading statement is unhelpful when we should be assessing this situation based on incidents that are actually impacting on our environment.
Welsh Government's approach aligns with the rest of the UK
Next up, the assertion that Welsh Government’s approach on NVZs aligns with the rest of the UK is simply not true. England (55% of land) and Scotland (14% of land) continue to designate discrete NVZs on the basis of evidence. If Welsh Government had based their regulations on the evidence undertaken by its own regulator, Natural Resources Wales, the designation in Wales would be somewhere between 2.3% and 8%. Although Northern Ireland has adopted a whole territory approach, farmers there received £140m of public funding at a grant rate of 60%. Which leads me on to…
Financial support is being made available to help farmers
The government’s claim that financial support is being made available to help farmers with the new regime. The Minister has announced just £11.5m of investment support despite the impact assessment identifying that £360m will be needed in upfront capital expenditure. This level of investment is woefully inadequate and suggests a worrying lack of understanding of the impact of these regulations.
The industry has not done enough
Another misleading claim made by Welsh Government, seemingly as further justification for the flawed approach that has been adopted, is that the industry has not done enough. As President of NFU Cymru I, along with NFU Cymru staff and officeholders, have committed a significant amount of time and resources to work, in good faith, with the Minister and her officials to put forward evidence for workable alternatives to the all-territory NVZ conclusion which has been reached. In fact, NFU Cymru led a project, part-funded by Natural Resources Wales, that developed the Water Standard, a Farmer-led Approach to Nutrient Management, but despite presenting the standard to the First Minister and Rural Affairs Minister nearly a year ago, we have yet to receive a substantive reply from Welsh Government. The expert, cross industry advice and recommendations put forward by ourselves and wider industry have not been heeded and, in some cases, not acknowledged and ignored altogether. Credible and viable innovative flagship approaches have not been backed with funding.
Throughout the numerous attempts to implore Welsh Government to follow the evidence NFU Cymru has, simultaneously, continued to engage with the farming community to raise awareness of the importance of action to improve water quality to farmers across Wales. The union has hosted farmer meetings and attendance at shows across Wales and providing information on the NFU Cymru website and its in-house membership magazine, Farming Wales magazine. The minutes from government meetings, the reports we have filed and the evidence we have gathered and presented show that NFU Cymru has driven a genuine, concerted industry effort to work with government on this important work, but that intention and goodwill has not been reciprocated by a government unwilling to engage with the available evidence.
Owing to the fact that Welsh Government’s own impact assessment has not assessed the extent to which levels of agricultural pollution are expected to decline as a result of the introduction of the all-Wales NVZ approach, we are extremely fearful that, based on the evidence we have seen and have highlighted to government, these regulations will not deliver the improvements we all want to see to water quality in Wales - but they will result in damaging consequences for many farming businesses and the wider rural economy. Let me be clear - the effects of these regulations will impact far beyond the farmgate as highlighted by the fact that last month, in an unprecedented move, 50 organisations from across the farming and the supply chain wrote to the Minister agreeing that whilst regulation should form part of the solution to tackling water quality, the NVZ approach should not be taken forward.
Our work on water quality since 2016
High Court dismisses NFU Cymru case against Welsh Agricultural Pollution Regulations
NFU Cymru finalising preparations to launch legal challenge over ‘damaging’ NVZ regulations
NFU Cymru begins a campaign to urge Members of the Senedd to vote against damaging NVZ regulations
Nearly 12,000 emails are sent to MSs from concerned farmers urging them to vote against the regulations.
The motion to annul all-Wales NVZs was narrowly lost in the Senedd on 3 March .
Joint letter by farming and supply chain organisations to the Minister for Environment, Energy and Rural Affairs
A broad coalition of organisations across farming and the supply chain who have an interest in a thriving and sustainable food and farming industry in Wales wrote to the Minister. All agreed that farming’s role in improving water quality must be central to that vision. Whilst the evidence shows that agriculture is not the only factor affecting water quality in Wales, we are clear that farming has a key role to play in reducing its impact through addressing current levels of point source and diffuse pollution.
The Farmer-led approach to nutrient management concludes with findings and proposals for Welsh Government
This project was funded by NFU Cymru and NRW with support on the project Steering board from Dwr Cymru, Welsh Government and Farmers’ Union of Wales. The project aimed to collate the industry's appetite to engage with water quality on farm through good nutrient management and the understanding of risk within their holding from diffuse and point source pollution. This culminated in the creation of the Water Standard document.
Results of FOI request by NFU Cymru cast further doubt on NVZ proposals
Information obtained by NFU Cymru from NRW added to the union’s growing concerns that a decision on Welsh Government’s all-Wales Nitrate Vulnerable Zone proposals was being taken without a comprehensive understanding of costs and impacts. In response to a Freedom of Information (FOI) request for information on the advice and evidence provided by NRW to Welsh Government relating to regulatory proposals, NRW supplied its comments on the adequacy of the draft Regulatory Impact Assessment (RIA); also making a number of points in relation to reputational risks to NRW and Welsh Government should a whole territory NVZ approach be taken forward.
NFU Cymru produces NVZ lobbying document
NFU Cymru continued to stress that any decision by Welsh Government on future water quality regulations must be made based on the available evidence, science and a robust impact assessment.
NFU Cymru asks for information justifying NVZ approach to be made public
NFU Cymru called upon Welsh Government to make publicly available key information relating to the proposed introduction of Nitrate Vulnerable Zones (NVZ) across the whole of Wales in 2020.
NFU Cymru board calls out Welsh Government on proposed all-Wales NVZ approach
NFU Cymru’s Rural Affairs Board criticised Welsh Government on its plans and approach to introducing an all-Wales Nitrate Vulnerable Zone (NVZ) in Wales
NFU Cymru outlines lack of preparation by Welsh Government for proposed NVZ approach
Information obtained by NFU Cymru under an official information request highlighted significant deficiencies in Welsh Government’s preparations for the proposed introduction of all Wales Nitrate Vulnerable Zone (NVZ).
Briefing on Welsh Government Written Statement
This briefing provided an update for members following the Welsh Government Written Statement.
Summary of evidence to Minister
NFU Cymru submitted available evidence to the Minister which included analysis of a broad range of environment, economic, social and cultural factors.
Royal Welsh Show dedicated water quality seminar
NFU Cymru held a dedicated seminar at the Royal Welsh Show to discuss water quality and the voluntary farmer-led approach to nutrient management.
Industry-wide project group, spearheaded by NFU Cymru looks at nutrient management best practice
The initiative, the first of its kind in Wales, was led by Water Quality/Nutrient Management Project Manager Lorna Davis and overseen by two key stakeholder groups; the project steering board and the water quality task and finish group.
NFU Cymru advances legal concerns over new rules
Following the release of the details of the new regulations by Welsh Government and subsequent meetings with the Minister for Environment, Energy and Rural Affairs, Lesley Griffiths, NFU Cymru’s lawyers, working with legal panel firm JCP Solicitors and Counsel, raised with Welsh Government their concerns about the lawfulness of the proposed approach. Alongside NFU Cymru’s legal arguments, the Union flagged other worries about the new proposals.
NFU Cymru appoints Lorna Davis to the position of Water Quality/Nutrient Management Project Manager
The position was joint-funded with Natural Resources Wales and focussed on taking forward the work of the NRW Agri-Pollution Sub Group to develop farmer-led voluntary approaches to nutrient management. Lorna’s appointment was evidence of the ambition within NFU Cymru, and indeed the Welsh agricultural industry, to provide workable, farmer-led solutions to the issues affecting water quality in Wales.
Written Statement by Minister Lesley Griffiths on Agricultural Pollution and Regulatory Reform
The Minister outlined her intention to introduce regulations to tackle agricultural pollution that will apply across the whole of Wales. The regulations were set to come into force in January 2020, with transitional periods for some elements to allow farmers time to adapt and ensure compliance. The regulations will include the following measures:
- Nutrient management planning;
- Sustainable fertiliser applications linked to the requirement of the crop;
- Protection of water from pollution related to when, where and how fertilisers are spread; and
- Manure storage standards.
NFU Cymru arranges for Carmarthenshire farmers and fisherman come together to discuss ways to improve water quality
‘Farmers and fishermen have a shared interest in the condition of our water courses and are committed to working together to maintain and enhance water quality in Wales’. That was the message from NFU Cymru and the Carmarthenshire Fishermen’s Federation at a special farm walk held on-farm in Cwmifor, Llandeilo.
NFU Cymru submits its vision for improved water quality in Wales
The role of Welsh agriculture in maintaining and enhancing water quality in Wales was set out by NFU Cymru in their paper entitled ‘A vision for improved water quality in Wales’. The paper, shared with Welsh Government and NRW, identified the immediate opportunities to support the sector to make water quality improvements through a series of twenty recommendations around the themes of advice and guidance; improved investment support; as well as facilitating the uptake of technology and innovative approaches.
Written Statement by Minister Lesley Griffiths on the NVZ consultation
In this statement the Minster stated that she was minded to introduce a whole Wales approach to tackling nitrate pollution from agriculture.
Union puts forward 'workable alternative' to further NVZ designation
NFU Cymru urged Welsh Government to consider a ‘workable alternative’ to reducing nitrates from agriculture to prevent further extension of Nitrate Vulnerable Zones (NVZs) in Wales.
The new option put forward by NFU Cymru was designed by farmers and builds on an off-set scheme that has been operating successfully by a group of First Milk dairy farmers in the Cleddau Catchment in Pembrokeshire.
NFU Cymru’s NVZ consultation response
NFU Cymru responds to the Welsh Governments Nitrate Vulnerable Zones in Wales consultation.
NFU Cymru’s briefing event at the Senedd
NFU Cymru held a briefing event with Assembly Members to reveal the results of a survey showing members’ strong opposition to Welsh Government’s NVZ proposals.
NFU Cymru polls farmers on NVZ proposals
NFU Cymru joined forces with a Pembrokeshire campaigner to canvas views on the Welsh Government’s NVZ proposals. The survey collated views and helped further understand the impact across the agricultural sector of the proposals put forward as part of Welsh Government’s consultation on the Nitrate Directive in Wales.