NFU Cymru has called upon Welsh Government to make publicly available key information relating to the proposed introduction of Nitrate Vulnerable Zones (NVZ) across the whole of Wales in 2020.
This includes full disclosure of the advice and evidence received by Welsh Government from Natural Resources Wales (NRW) and Welsh Government’s Regulatory Impact Assessment.
NFU Cymru is disappointed that as part of a Freedom of Information request under the Environmental Information Regulations, Welsh Government has refused to disclose the advice and evidence relating to the proposed regulations that it has received from NRW.
NFU Cymru Deputy President Aled Jones said: “Clearly this decision is very disappointing. As environmental regulator and adviser to government, NRW will play a key role in the application of the EU Nitrates Directive in Wales if the Minister decides to implement this directive. NRW is also the enforcement body for NVZ rules which, if the current proposals are taken forward, will apply to every farm business across Wales.
“Information supplied by NRW as part of the Nitrates Review in 2016 provided no justification for the introduction of NVZs across the whole of Wales. We believe it is very much in the public interest to understand what information Welsh Government has received from NRW since then to lead Welsh Government to such a costly and damaging NVZ proposal. It is also legitimate to understand whether Welsh Government whole Wales NVZ proposal aligns with the advice of the principal adviser to government on all matters relating to the environment and natural resources.”
NFU Cymru has also repeatedly expressed concerns about the way in which the proposals for the introduction of regulatory measures to address agricultural pollution have been developed without a thorough understanding of the costs and impact of the proposals.
NFU Cymru Deputy President Aled Jones said: "The Regulatory Impact Assessment is a critical document in understanding the impact of regulatory proposals. The significant importance of this assessment and potential long term implications, calls for a high level of scrutiny. No decision should be taken without a comprehensive understanding of the full impact of that decision."
NFU Cymru has written to the Minister for Environment, Energy and Rural Affairs, Lesley Griffiths AM to reiterate the key factors that it believes should be considered as part of a comprehensive Regulatory Impact Assessment.
Mr Jones said: “A comprehensive impact assessment must consider the impact of an all Wales NVZ on farm viability and capacity of farm businesses to afford the cost of new regulations and continue trading, alongside consideration of the impacts of proposed NVZ regulations on employment, both direct and indirect, on Welsh farms as well as in the allied industry and wider supply chain.
“This assessment is crucial when you consider that these regulations could be implemented against the backdrop of latest figures on Farm Business Incomes in Wales (2018-2019), which have shown drops in income of 43% on dairy farms, 30% on cattle and sheep (LFA) farms and 29% on cattle and sheep (lowland) farms.
“The impact assessment must also take account of specific sectoral impacts including the dairy and specialist beef sectors, as well as the ability of tenant farmers and farmers suffering long term Bovine TB breakdowns to reach compliance with NVZ regulations.
“The full cost and impact of the regulations must be considered alongside a similar comprehensive assessment of the benefits to Water quality that the EU Nitrates Directive would deliver in Wales.”
Mr Jones added: “The proposed new regulations will impact on every farm, every sector and every area of Wales and their proposed introduction is contributing considerably to high levels of stress and anxiety within the farming community at, what is already, an exceedingly difficult time.
“On the basis of the evidence that NFU Cymru has collated and presented to Welsh Government we categorically reject proposals for an all Wales NVZ approach; we believe that it will not be effective in delivering water quality improvements and that it will be highly damaging for farm businesses and the wider economy. We believe that it is highly rational and legitimate that NFU Cymru, on behalf of its members, request that Welsh Government make publically available the information and evidence it has to justify whole territory NVZ proposals.
“We accept that a regulatory backstop may be needed but this must recognise and take account of the regulation that is already operational in this sphere and it must be evidence-based, proportionate to the risk and targeted to areas where water quality improvements are needed. NFU Cymru is committed to working with government and all those with an interest in water quality in Wales to support the farming industry to make the improvements where these are needed.
“NFU Cymru is hugely ambitious for the future of Welsh farming. Our primary production underpins the £6.8 billion food and drink industry and we believe that our dairy and beef sectors can be world-leading, given the right policy framework. NVZ regulations will undermine and stifle this ambition and as such we urge Welsh Government to share our ambitious outlook by recognising the limitations of an NVZ approach and put in place a system that improves the environment whilst enabling our industry to reach its full potential.”