MEASURES TO PROMOTE CATCHMENT-SENSITIVE FARMING”
Rivers Trusts (RT) is the representative body of the
Rivers Trust movement in England and Wales and also
provides an “umbrella” for many community
based river improvement groups, initiatives and projects.
RT has an MOU with its sister body in Scotland, “River
and Fisheries Trusts Scotland” (RAFTS).
The Association of Rivers Trusts 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. It changed it's name to The Rivers Trust in August 2011. 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.
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.
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
In the context
of charitable purpose and public benefit, the objects
of RT are to:
To co-ordinate, represent, support and develop the
aims and interests of those involved in the promotion
Sustainable, holistic and integrated river catchment
(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.
To advance the education of the public, or any association,
company, local authority, administrative or governmental
agency or public body or representative body in: -
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.
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).
Pollution from Agriculture (DWPA) & Catchment
Sensitive Farming (CSF)
RT 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.
supports the development and promotion of the Catchment
Sensitive Farming Programme (CSF)
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 RT 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.
Do you agree that there is a significant problem with
agricultural emissions to water that will require action
beyond current and planned policies?
Yes - we agree strongly.
We all benefit socially and economically from a healthy
environment. Although in general, thanks to tightening
legislation and enforcement by government and its agencies,
industrial and point pollution is a reducing problem,
diffuse pollution from agriculture has become more visible.
The presence and damaging effects of diffuse pollution
have been exacerbated by CAP “blanket” agricultural
subsidies previously linked to production. The “downstream”
economic consequences of which often far outweigh any
agricultural, social or economic benefit originally
intended. These impacts may manifest themselves in many
increased risk of intermittent point pollution,
diffuse pollution (including microbiological contamination),
declining soil infiltration rates,
erosion and sedimentation,
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 RT 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 RT 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.
diffuse pollution is the major issue affecting many
insufficient progress is being achieved in relation
to its reduction and
pollution will detract from or eradicate the benefits
of other improvement works. (e.g. habitat improvement,
that the economic consequences of diffuse pollution
are greatly underestimated:
relation to meeting other EU Environmental and Health
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
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).
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”
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
also need to provide a stronger package for tenant
farmers and other distinct groups or producers.
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?
RT endorses the
need for action set out in Section 1 and believes
there are a number of
aspects of evidence that require extra investigation:
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.
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.
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.
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.
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:
or strategic importance as a provider of ecological
or environmental services (e.g. reservoir catchment).
use and fluvial geomorphology.
cost benefit v risk reduction.
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 RT believes
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.
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
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
Yes- RT strongly agrees
on the need to address farm inputs, land management
and land use.
RT 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.
is the planning and targeting process together with
the predicted response to various farm support “packages”
that is necessary to achieve cost benefit.
practices recommended include:
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
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
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
given to the reduction of P by manufactures in livestock
feed rations- unless specified
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.
Do you agree with the proposal to take early action
to promote catchment-sensitive farming to:
pressing water quality and conservation targets -
help farmers to prepare for forthcoming regulatory
requirements - yes
pilot action and improve our knowledge to the action
required - yes
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”.
may be a case for testing approaches on catchments
where there are existing projects or strong advice
networks or particular social cohesion between farmers.
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:
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?
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.
2: Early Regulation
Option 2 is preferred by RT 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.
3: The Supportive Approach
Option 3 is the preferred option of RT in concert
with Option 2 above, to include a package of tools
and measures including:
of information and development of skills amongst farmers.
planning and advice.
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
RT 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.
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?
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!
economic instruments or incentives including capital
grants, tax allowances and agri-environment schemes
should also receive consideration.
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
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.
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
what would be the optimum package of policy instruments
promoting catchment-sensitive farming?
RT would chose
f (a supportive package with some early regulation)
as the first step toward promoting catchment-sensitive
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?
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
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.
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 RT‘s experience
that it is the targeting of funding and effort that
is the key to cost effective results
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
Yes – but in RT’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.
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.
In addition to the responses above, RT 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.
implementation of the Ecosystem Approach & Bio-regional
planning fully integrated at the river basin or catchment
development of a fully functioning retail market capable
of supporting sustainable agricultural production
with an understanding of CSF.
empowerment of positive stakeholder action and opportunity
for greater partnership between government, its agencies
and NGO’s to deliver CSF measures cost effectively.
recognition of an overarching aim to develop the tools
to meet market needs and current and forthcoming EU
that the legacy of previous adverse environmental
practice will take time to ameliorate, and monitoring
will need to take this into account.
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.”