Senedd Cymru	Welsh Parliament
Pwyllgor yr Economi, Masnach a Materion Gwledig	Economy, Trade, and Rural Affairs Committee
Rheoliadau Llygredd Amaethyddol	Agricultural Pollution Regulations
Economy(6) APR05
Ymateb gan: Ymateb unigol	Evidence from: Individual response

The all-Wales approach acknowledges that it is not only SACs that are affected by excess Nitrate and Phosphate pollution, but all water courses, Ultimately water pollution, whatever its origin feeds into major rivers.

The policy has not been welcomed by the agricultural community as it is "imposed" and farmers do not like being told what to do. The apparent "knee-jerk" manner in which the policy was announced has led to widespread criticism, and an assumption that it is eroding the freedom of farmers to do what they have always done.

The current approach needs to be implemented as part of a wholesale revamping of agriculture systems. The adoption of more intensive agriculture, including the increased use of inorganic fertilisers, coupled with reseeding and increased field drainage, has led to increased runoff. Excess plant nutrients, from slurry, fertilisers and farm yard manure are easily washed into water courses. While the proposed management system relies on on-farm assessment of ground conditions, farmers are unlikely to provide objective reliable assessment of ground conditions.

The current review of agricultural policy in Wales needs to adopt a more sustainable and ecologically sensitive approach to food production which includes pollution control. This would comply with the Well-being of Future Generations (Wales) Act 2015. Specific regulations should include the restriction of the expansion of intensive livestock units, especially Intensive Poultry Units and the location of large dairy farms. Grazing livestock should be excluded from all watercourses and the application of inorganic fertilisers limited to the amount required by the growing crop.

Placing a country-wide ban on all activities which could possibly lead to nitrate (and phosphate) pollution is not practical as existing farming systems are unlikely to be able to conform. Enforcement would be dependent on an under-resourced NRW.

A coherent, inclusive and far reaching agricultural policy is the best solution..

Regards,
Piet van den Ende