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) APR12

Ymateb gan: Cymdeithas Bysgota Pontardawe ac Abertawe Cyf

Evidence from: Pontardawe and Swansea Angling Society

Our Ref: PASAS2021-09-03

Pontardawe & Swansea Angling Society is a respectable not-for-profit angling club with approximately 200 members, formed in the 1940s and incorporated as a company limited by guarantee in 2010. We own, control or enjoy the fishing on about 8 miles of the lower River Tawe.

We are concerned with continuing agricultural diffuse pollution and the failure of water bodies to reach both good ecological and chemical status (as defined under WFD) in Wales.

At present in Wales, 60 of waterbodies in Wales are failing to reach their statutory targets because of the high levels of phosphate which come primarily from agriculture.

One of those waterbodies, the River Wye (an SAC with numerous SSSI's in its catchment) has been blighted by algal blooms caused by pollution from the poultry industry high up in its headwaters where there are no other phosphate inputs. The Welsh Government and its agencies remain in denial over the problem as well as avoiding the logical conclusion as to cause - with the outcome being that little if anything has been done to stop the influx of phosphates to this and other rivers in Wales.

In recent years the rivers of West Wales have also suffered badly from numerous farm pollution incidents.

Most Welsh rivers also have significant issues of sewage discharges, mainly from Dwr Cymru Welsh Water operations, adding to the phosphate and nitrate burden of waterways.

We therefore welcomed the introduction of the Water Resources (Control of Agricultural Pollution) (Wales) Regulations 2021 which come belatedly on the heels of the English farming rules which were introduced in April 2018.

However, in the light of the Welsh Senedd vote on annulling the regulations in March 2021 and the recent National Farmers' Union Cymru legal challenge, we would emphasise that we do not believe that these regulations are disproportionate or that there was any unlawfulness in the process by which they came into force.

We note that the NFU suggest that "farmer-led voluntary initiatives;.... supplemented by targeted and proportionate regulation" would be sufficient (https://www.nfu­cymru.org.uk/news/latest-news/nfu-cymru-finalising-preparations-to-Iaunch-Iegal­-challenge-over-damaging-nvz-regulations/) to deal with agricultural diffuse pollution.

It is clear from farming pollution incidents across Wales in recent years and what has happened in England - in particular with sensitive sites in agricultural areas suffering from agricultural diffuse pollution and where the sites are failing to meet favourable status - that voluntary measures alone do not work.

The Welsh Regulations are far more comprehensive and far reaching than their English equivalent and provide a sweeping basic measure to prevent pollution.  As a result we support the Regulations and believe that they should be implemented and enforced across the Principality. But they must be revised to include all forms of agricultural pollution as a standard for the whole of Wales. We see no alternatives to regulation. Above all, sufficient resources need to be ring-fenced for their enforcement.

Yours faithfully

Ray Lockyer
Director, Life President and Secretary.