Submission date: 9th September, 2004

Association of Rivers Trusts (ART)
Response to the joint Defra-HM Treasury consultation on:
“DEVELOPING MEASURES TO PROMOTE CATCHMENT-SENSITIVE FARMING”

ART was publicly launched in 2001 as a national body by the Eden Rivers Trust, Tweed Foundation, Westcountry Rivers Trust and Wye & Usk Foundation, and joined shortly after by the Ribble Catchment Conservation Trust. Other leading trusts now include Wessex Salmon & Rivers Trust, Trent Rivers Trust, Dee Rivers Trust, Pembrokeshire Rivers Trust, River Wear Environmental Trust and Thames 21. All member Trusts are registered charitable trusts and each has made a significant contribution in their own areas to improve the aquatic environment and river basin management for public benefit.

Rivers trusts have been described as having “wet feet” because they have the reputation of being “doers” concentrating much of their effort on practical catchment, river rehabilitation and fishery improvement works on the ground. Many rivers trust projects are based on partnerships and, in England and Wales, trusts work particularly closely with the Environment Agency, English Nature, Countryside Council for Wales and Defra on a regional basis.

Rivers Trust funding comes from a variety of sources including community public fundraising, with many projects being part funded by government and its agencies (including the Landfill Tax Credit Scheme) and through EU structural funds including, Objective 5b, 1, 2, LEADER, LIFE and Interreg.

In the context of charitable purpose and public benefit, the objects of ART are to:

(A) To co-ordinate, represent, support and develop the aims and interests of those involved in the promotion of: -

(1) Sustainable, holistic and integrated river catchment management.
(2) Sound environmental practices relating to the protection, use and conservation of water, whether freshwater, marine or brackish and whether running, tidal or still waters.
(3) The wider economic benefits for local communities that may be derived from the foregoing, including, without prejudice to the generality of the foregoing, angling and other forms of sustainable recreation.

(B) To advance the education of the public, or any association, company, local authority, administrative or governmental agency or public body or representative body in: -

(1) The understanding of rivers, river corridors and catchments, including their fauna, flora and economic or social activity, and river catchment management.
(2) The need for, and benefits of, conservation, protection, rehabilitation and improvement of aquatic environments.

(C) To conserve, protect, rehabilitate and improve the rivers, streams, watercourses and water impoundments of England and Wales or any part or parts thereof (including involvement in projects thereon, whether or not in association with partnerships within England and Wales or elsewhere).

Diffuse Water Pollution from Agriculture (DWPA) & Catchment Sensitive Farming (CSF)
ART strongly welcomes the “Tackling Water Pollution from Agriculture” consultation which includes a range of potential measures to combat agricultural water pollution, outlined by the Government.

ART strongly supports the development and promotion of the Catchment Sensitive Farming Programme (CSF)

CSF Overview
A utilitarian approach to river basin use harms both catchment integrity and supportive capacities. Land use pressures, industrialisation and urbanisation have massively modified landscapes, with consequences for the quality and character of aquatic environments.

Water quality management has focused upon point source control, delivering significant improvements but also exposing the significance of diffuse inputs. Yet point sources have remained the focus for control as they are easy to identify, model and regulate. The significance of diffuse pollution has long been overlooked. Its characteristics differ significantly from point source pollution, often occurring in discrete ‘episodes’ yet with consequences that are long-lasting. This “spiking” pattern is difficult to identify, trace and measure, but it is critical to understanding environmental impact on a catchment basis.

Abstraction of water has often been undertaken under the flawed notion that ecosystems contain ‘spare’ exploitable water over and above a minimum amount ‘used’ by nature. The reality is that nature is the net provider of water.

A fundamental reappraisal of our relationship with the water environment cycle is necessary if it is to continue to support society.

The EU Water Framework Directive (WFD) is significant in placing the ecosystem at the heart of management, with ecological problems addressed in an integrated manner. It changes the paradigm of regulatory approach, also including requirements for public participation. However, there are concerns about the extent to which this change is being addressed in transposition into UK law and practice.

To succeed it is essential that CAP reforms and other policy measures are aligned to assist in the meeting and delivery of the WFD and other related Directives this includes adopting a river basin or catchment approach to planning and targeting expenditure and effort. The work of ART member trusts working in partnership demonstrates what may be achieved by putting the ecosystem centre-stage, and maximising the socio-economic benefits through a process of public participation.

Response to Questions

• increased risk of intermittent point pollution,

• diffuse pollution (including microbiological contamination),

• declining soil infiltration rates,

• run off,

• erosion and sedimentation,

• eutrophication,

• wetland loss,

• flashy flows with associated increased flood risk,

• falling water tables and the loss of biodiversity,

• and the denuding of habitat and landscape.

It is estimated that water consumers now pay an average of £7.00 each (ref: ADAS) to remove nitrate and pesticides from drinking water supplies; with industry experts expecting charges to increase significantly in the next few years.

With this in mind ART strongly welcomes the recent reforms announced by Defra including the de-coupling of subsidies from production in favour of the Single Payment Scheme with strengthened cross compliance, the introduction of new expanded Entry Level and Higher Level Stewardship Schemes and Farm Planning and Advice initiatives. However it is the view of ART that even this is unlikely on its own to provide sufficient positive encouragement, knowledge and the incentives needed for farmers who are making a living as best they can, particularly in the upland areas.

ART believes that:

• diffuse pollution is the major issue affecting many rivers,

• insufficient progress is being achieved in relation to its reduction and

• diffuse pollution will detract from or eradicate the benefits of other improvement works. (e.g. habitat improvement, increased access).

Furthermore that the economic consequences of diffuse pollution are greatly underestimated:

• In relation to meeting other EU Environmental and Health Directives.

• In relation to the costs of drinking water supply.

• When comparing the impacts on tourism, for example, the former being worth some £10 billion v agriculture’s £3.5 billion (which is heavily subsidised).

• When the value of angling alone is not inconsiderable.

• In summary, this means that the “taxpayer currently pays 3 times” (for the farm product, subsidy & “clean up” cost).

Further recommendations for CAP and policy reform should include:

• More support for the positive protection of environmental and ecological service providers that each community relies on, including, clean air and plentiful water, productive soils, reduced risk of flooding and biodiversity. This is important for health, quality of life, tourism and many forms of natural resource based development, not least angling (requiring an “abundance” of fish).

• Reform needs to be more comprehensive than the announced new package of measures and Agri-Environment schemes alone, which have admittedly not yet had opportunity to prove themselves, but are likely to be found wanting. With limited resources, a greater degree of focus on outcomes and targeting is still necessary. Both the Entry Level and Higher Level Schemes are still largely targeted toward conservation of species and habitats rather than ecology and environment, they as their predecessors are likely to find their benefits fragmented as they are not designed to apply at a catchment scale. Greater emphasis should also be placed on incentives to engage groups of farmers to work together providing synergy and “critical mass” again preferably at a sub–catchment scale. They should be encouraged to be focused on outcomes, share responsibility and be self policing. The present CSS group scheme on Blisland Commons, Bodmin Moor has elements of this approach already (recently recognised by English Nature).

• The preferred delivery method would be via a combination of whole farm plans and group schemes with targeted payments integrated at the River Basin scale, beginning with the identification and protection of key headwaters, groundwater recharge zones and water supply reservoir catchments and areas that may provide flood alleviation or relief. The provision of buffered corridors for water transmission may also be added to link up fragmented habitats.

• Reforms also need to provide a stronger package for tenant farmers and other distinct groups or producers.

• Reforms will need to address new challenges including the “1000+ cow dairy herd”, the greater general reliance on agricultural contractors within the industry, low input “ranching systems” and anticipate other market moves and forces.

• Many in the environmental movement still feel that the Environment Agency have insufficient powers (or a reluctance to use them) in relation to the prosecution of farmers for causing both point and diffuse pollution. Particular areas of concern are the gathering of evidence where the pollution is not accompanied by the proven death of fish and in relation to the impacts of high sediment loadings.

Q2. Which aspects of the evidence presented in Section 1 do you think require extra investigation as a basis for policy development?
ART endorses the need for action set out in Section 1 and believes there are a number of
aspects of evidence that require extra investigation:

1. It is critically important better to understand and recognise the legislative pressures and domestic and international targets that will demand change and identify their specific requirements at a catchment as well as regional scale. These include WFD, Bathing Water Directive, Habitats Directive, Nitrates Directive, Freshwater Fish Directive etc.

2. There is a need to recognise and understand better societal pressures for change where many believe the current system of agriculture is neither sustainable nor equitable. Both consumers and producers want change and many communities, including farmers and riparian owners, feel disenfranchised.

3. There is the need to consider the response to concerns on climate change, which is likely to exacerbate diffuse water pollution from agriculture through drought and intensive rainfall events.

4. The need for improved environmental and ecological health indicators and monitoring, particularly in relation to the measurement of turbidity, sediments and their contaminants. Intermittent or episodic pollution events often escape detection and can lead to a completely false environmental picture.

5. The need for improved economic indicators to measure indirect cost benefits and attach values to environmental and ecological service provision.

6. The need to investigate and develop methods to target activity by catchment so as to be more cost effective. Targeting may be based on:

• Compliance.

• Designation.

• Significance or strategic importance as a provider of ecological or environmental services (e.g. reservoir catchment).

• Land use and fluvial geomorphology.

• Relative cost benefit v risk reduction.

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?
In simple terms ART believes not.
Based on the experiences of member trusts (e.g. Westcountry Rivers Trust) in the delivery of catchment land use projects, it is clear that many farmers fail to access the information and skills required to respond to the causes and effects of agricultural emissions to water and to develop and implement solutions. However once the guidance, information and skills are delivered on a “face to face” basis farmers respond remarkably well. Engaging the farmer is the key, not the amount of information that is freely available nor its quality, which is generally excellent. This is highlighted in a “customer satisfaction” study carried out for Westcountry Rivers Trust as part of its Cornwall Rivers Project. It showed that farmers greatly valued the “Whole Farm Plans” and advice the project offered, which is bespoke and relevant to them, as much as the (up to 40%) small grants available for river bank protection.

The Westcountry Rivers Trust’s Tamar 2000 Project and Westcountry Rivers Project also involved catchment targeted approaches. These offered free Whole Farm Plans, looking at the problem of reducing farm waste and “leakage”, and from the farmer’s perspective- seeking “win-win” opportunities. These farm studies even on otherwise well managed farms consistently found wasteful use of fertilisers and an underestimation of soil index and manurial values on farm, particularly in the case of P. This was found to be largely due to lack of awareness and lack of soil testing particularly on non arable livestock and mixed farm units. The project's concluding economic study shows that with the right information most farmers will take action to reduce over or wasteful application of fertilisers and choose to save money instead! At a catchment scale the multiplicative effect of these small savings and/or gains are considerable in both economic and environmental terms.

Similar findings relate to soil management, which is central to the transport of P, and often has massive associated "downstream" costs. The value of wetlands is another similar issue, particularly when incorporated as buffers, and were identified as providing extensive de-nitrification.

The economic reports of both projects show an overall potential direct saving/ gain of around £2000 / farm / year, based on applying the advisors recommendations on fertilisers alone. The actual benefits found in the economic report sample (based on the willingness and success of farmers acting on the advice) were of between £956 / farm /year (Westcountry Rivers Project) & £312 /farm /year (Tamar 2000 Project)

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- ART strongly agrees on the need to address farm inputs, land management and land use.
ART recommends a strategy of applying an Ecosystem Approach based bio-regional plan at the river basin scale, in effect “integrated river basin planning”. This would allow the co-ordination of effort between government departments, agencies, local government and NGO’s together with the effective targeting of incentives, advice and support at the catchment / sub catchment scale, delivered where priority dictates via a range of communication methods, including training, advice and Whole Farm Plans.

• It is the planning and targeting process together with the predicted response to various farm support “packages” that is necessary to achieve cost benefit.

Priority farm practices recommended include:

• Consideration should be given to producing fertiliser /nutrient plans (including soil testing) for farms, alongside the soil management plans required from 2007 under cross compliance. It is essential that these both integrate and address the phosphorous “time bomb”

• Protection of watercourses from agricultural activities including direct livestock access (if necessary through the selective use of extended buffer strips, regulated grazing and exclusion through fencing) should receive greater consideration as should the importance and management of strategic wetland buffer-zones including ditches

• The adoption of “Best Practice” should be actively encouraged and practical land and riverbank management protocols for advisors, farmers and riparian owners agreed between government departments, agencies and NGO’s

• Consideration given to the reduction of P by manufactures in livestock feed rations- unless specified

• As previously raised in the response to Q1, consideration should be given to the implications of the “1000+ cow dairy herd”, outdoor pig stocking densities, the greater general reliance on agricultural contractors, low input “livestock ranching systems” and anticipation of other market moves and forces, including the short term lease contract growing of potatoes and other crops.

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 - yes

b) help farmers to prepare for forthcoming regulatory requirements - yes

c) pilot action and improve our knowledge to the action required - yes

Q6. Do you agree with the proposal to begin any targeted action in priority conservation catchments?
Yes- However with the proviso that these catchments may not necessarily demonstrate the greatest response to the proposed “actions” both in terms of improved water quality or cost benefit. For example this may be better demonstrated where there is a particular farming problem, e.g. intensive dairy units or outdoor pigs or a higher level of environmental and ecological service provision with strong economic consequences e.g. catchments with a high level of abstraction requiring treatment, a community subject to flooding linked to agricultural land use, a valuable fishery in decline or with its beaches failing to meet bathing water standards with the potential to achieve “Blue Flag”.

Lastly, there may be a case for testing approaches on catchments where there are existing projects or strong advice networks or particular social cohesion between farmers.

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: Existing Policies and Late Regulation
Under Option 1, the risk of failing to meet targets is high and the opportunity to develop and test integrated Catchment Sensitive Farming systems and methods of delivery is limited. Late regulation may require greater emphasis on blunt national control systems, whereas early regulation may provide greater opportunity for voluntary/ incentive based targeted catchment or sector approaches. The recent CAP reforms and the Single Farm Payment Scheme have provided a watershed for farmers who are giving considerable thought to their future plans. It is important to provide strong signals at this time to assist their decision making process.

Option 2: Early Regulation
Option 2 is preferred by ART over Option1, for the reasons stated above and in particular is supportive of Area-based and Targeted Regulation tools where forming part of a river basin bio-regional plan.

Option 3: The Supportive Approach
Option 3 is the preferred option of ART in concert with Option 2 above, to include a package of tools and measures including:

• Voluntary action.

• Provision of information and development of skills amongst farmers.

• Grant –aid.

• Farm planning and advice.

ART believes that its members and other NGO’s working in concert with government and its agencies could make a major contribution to this approach.

Option 4: Economic Instruments
ART is less supportive of the use of economic instruments than Options 2 and 3. However there may be case for the thoughtful integration of these instruments in support of Options 2 and 3. The case for and against is argued well in the consultation paper.

• Fertilisers- most important is the need for farmers to soil test and develop and apply nutrient management plans. This is most likely to be achieved by making it a requirement of cross compliance and /or providing free access to tools and advice. A fertiliser tax is blunt and will alienate the agricultural industry at a time when it is already struggling financially, and when the central theme is surely to encourage farmers to adapt to the future together?

• It is essential that any economic instruments or schemes should be broadly fair, transparent, simple, cheap to operate and achieve their stated purpose. This is likely to preclude most in practice!

• Other economic instruments or incentives including capital grants, tax allowances and agri-environment schemes should also receive consideration.

• As the “stick” to balance the “carrot” of support, financial penalties should be targeted as now on transgressors on the “polluter pays” principle with fines generally higher as the true costs become better known.

b) do you think that a combination of policy instruments would be the best approach to catchment-sensitive farming?
Yes-Based on Options 2& 3

c) how would you rank the combined approaches in section 4.56 (4.69) in terms of effectiveness and acceptability? Please explain why you would prefer each approach to less favoured alternatives.

1.) f -likely to be effective and acceptable
2.) e - most acceptable to farmers and likely to be effective
3.) c - likely to be partially effective and acceptable
4.) g - acceptable to those outside farming, may fail to deliver and prove expensive to implement and monitor
5.) b - acceptable to those outside farming, may not be effective
6.) d - as b above
7.) h - as b above
8.) a – not acceptable or effective

d) what would be the optimum package of policy instruments
promoting catchment-sensitive farming?

ART would chose f (a supportive package with some early regulation) as the first step toward promoting catchment-sensitive farming.

Q8. What would you expect the overall and 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?

ART members’ experiences in the delivery of targeted catchment projects, which provide a package of supportive measures, including farm advice, farm plans and some grant support, indicate a positive project cost benefit ratio of around 6.4:1 (discounted at 6% over 10 years, the project paid for itself 6.4 times -Westcountry Rivers Trust).

Even though projects of this kind focus on “win-win” opportunities it is not unreasonable to conclude that, in concert with other CAP reform measures, cost benefit will be at worst cost neutral for all sectors, and likely to be strongly positive once indirect economic values are assigned.

ART strongly believes that promoting the potential for cost savings/gains is a powerful means of engaging the farming industry in a positive and realistic manner, and will foster an impetus for economic, environmental and societal change within the farmer himself at the same time engendering public support and benefit.

b) benefits; in particular in relation to the environmental effectiveness of the approaches?

If proper economic values can be assigned to the indirect environmental benefits accrued, to be shared by downstream communities, in most catchments benefits will be considerable, but, as stated previously, it is ART‘s experience that it is the targeting of funding and effort that is the key to cost effective results

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?
Yes – but in ART’s view they do not go far enough and currently lack sufficient “local” or catchment sensitivity. Thus, they may be sufficient for reporting to Europe but are not sufficiently developed to monitor success or failure of present and proposed measures or to detect which measures are working. A key example is that of monitoring erosion, turbidity and sediments.

Improved monitoring and catchment surveying techniques are also necessary for accurate, cost effective targeting of support packages, other “tools” and catchment pilot schemes. We have also previously referred to the issue of episodic events and the need better to understand their impacts.

Summary
In addition to the responses above, ART believes there is a need for:

• The development of a new clear vision for agriculture and the countryside that can be interpreted, shared and understood at all levels.

• The implementation of the Ecosystem Approach & Bio-regional planning fully integrated at the river basin or catchment scale.

• The development of a fully functioning retail market capable of supporting sustainable agricultural production with an understanding of CSF.

• The empowerment of positive stakeholder action and opportunity for greater partnership between government, its agencies and NGO’s to deliver CSF measures cost effectively.

• The recognition of an overarching aim to develop the tools to meet market needs and current and forthcoming EU Directives.

• Recognition that the legacy of previous adverse environmental practice will take time to ameliorate, and monitoring will need to take this into account.

• Concentration on quick wins, particularly those where cost savings can be clearly demonstrated in order to build credibility and a sense of achievement.

• A greater willingness by Government and its agencies to work in concert with regional initiatives and NGO’s like FWAG and Rivers Trusts and capitalise on existing knowledge, good-will and rolling projects to get best value from the new measures from “training to delivery” and to test new pilot schemes with a view toward a greater integration of effort to turn, “joined up thinking into joined up action.”

AJR/ART 09.09.2004