The NFU has submitted a list of 45 recommendations for alterations as part of its submission on the proposals, which it estimates will cost farmers hundreds of millions of pounds while doing little to improve the environment and causing other environmental problems as a result, such as the increased risks to soils, air and water of applying manures in the late winter and spring and an increase in carbon dioxide emissions resulting from compulsory sown cover crops
NFU Vice President Paul Temple said: 'The proposals put forward by Defra need to undergo wholesale changes before any thought is given to implementing them. We have argued for a long time that the EU Nitrate Directive is outdated. I can think of few people who would regard changes that will cost farmers £240 million of slurry storage for a 0.5 to one per cent reduction in nitrate leaching as rational or good value for money. Defra should be avoiding any additional burdens not adding to them.
'Many of the proposals in the directive are already being, or could be better, achieved using other legislation including the Water Framework Directive and Environmental Stewardship schemes. Farmers are keen to do all they can to minimise their impact on the environment while meeting their primary goal of food production.'
Among the key changes the NFU is demanding are:
• no revised action programme applied within the NVZs mis-identified in 2002 or where the Nitrates Directive objective of declining nitrate trends is already being achieved;
• closed periods should not extend beyond the end of November as the financial resource, energy costs and pollution swapping involved do not justify the diminishing returns in terms of nitrate leaching;
• similar grants to those offered to farmers in other parts of the UK to construct the thousands of new slurry stores these proposals will require;
• a minimum of four years should be allowed for the industry to comply with major constructional requirements;
• a joint submission with Defra addressed to the Commission making the case for a derogation from the 170 kgs N/ha whole farm organic manure limit;
• the removal of cover crop requirements from the NVZ action programme
Grants have been offered to assist livestock farmers to install slurry storage in previous NVZ designation exercises. In 2002 Defra offered 40 per cent grants to those needing to construct new stores. Scotland is offering grants up to this level as well. In Northern Ireland 60 per cent grant aid is available.
'We will continue to contest unnecessary, gold-plated regulation wherever we encounter it, and will be doing our level best to ensure that this decision sets a precedent for other examples of regulatory overkill, like the Government's proposals for implementing the Nitrates Directive.'