NFU Cymru has opposed Welsh Government proposals for new controls on the storage of oil which will require all non-domestic storage containers, with a capacity of more than 200 litres, to have a secondary containment system.
In its response to the recent consultation, NFU Cymru has highlighted that farmers in Wales are already regulated on the storage of oil and agricultural fuels through the SSAFO regulations.
Rural Affairs Board Chairman, Bernard Llewellyn said, “NFU Cymru has long argued that measures to improve water quality must be based on robust evidence. In the case of oil-related pollution incidents, the data shows there has been a downward trend of over 41% in the ten year period to 2014 and no sector specific evidence has been provided to make the case for additional regulation on the farming industry.
“We are disappointed that Welsh Government, through its Regulatory Impact Assessment, has not adequately recognised the regulatory controls and inspections that farmers in Wales are already subject to. We also do not agree with the assumption that the new regulations will place no additional burden or cost on farmers. This is simply not the case and a recent survey of our members has revealed that almost 43% of oil storage facilities were installed pre 1991, with 46% of respondents indicating that they had two or more tanks on their farms. The survey also revealed that over half of respondents said their storage tanks were located more than 100 metres from the nearest watercourse.”
Mr Llewellyn added, “The extent to which oil-related pollution incidents are a consequence of criminal activity, thefts or acts of vandalism, has also not been adequately considered within the proposals. Having a bunded tank makes little difference to the likelihood of oil spillage where the skin of the tank is deliberately breached so the proposed new standards for oil storage will not, on their own, be effective in mitigating the impact of criminal activity. A far more robust law enforcement response is therefore required.
“Farmers in Wales operate in an extremely complex regulatory framework and we see no benefit to adding to this complexity with additional regulation, particularly when this is not backed up by the evidence. Instead, we believe, Welsh Government should focus on the clear opportunities that exist to work in partnership with industry to drive improvements in oil storage should these be necessary.”