NFU Scotland have responded to a government consultation on the storage of silage, slurry and digestate and the application of slurry and digestate to land as fertiliser.
And they have highlighted significant and potentially damaging costs associated with the proposals.
Their first case study from this area comprises two businesses run over three holdings with 200 suckler beef cows. Half the cows are committed to ecologically beneficial SSSI managed grazing.
In four generations of farming there has never been a single pollution incident. Two months prior to becoming aware of this proposal, the farmer signed a new tenancy agreement, specifically to gain advantage from the holding’s existing pre-1991 accommodation for 220 head. This would no longer be compliant.
The financial commitment of this tenancy is well into six figures and the NFU warn that the proposed regulations would jeopardise that investment. They said: “It would be unrealistic for a SLDT tenant to invest large sums of capital for expensive infrastructure where there is no return on that investment, unless entirely grant funded.
“It would also be unfair to expect a landlord to contribute, when they similarly will have granted tenancies in good faith and who would be equally unlikely to see a return on their investment. The alternative options are very limited and will likely lead to the herd being sold.”
It’s believed the government’s measures would incur a pricetag of over £250,000 for the unit.
Elsewhere in the region, a 90 cow dairy enterprise run on 60 hectares could be facing £60,000 in costs under the proposal.
Approximately five years ago, it became part of an NVZ area, which required a new slurry store to meet storage requirements.
The farmer believes that under the proposals further investment would be needed to upgrade the silage pit and FYM storage and run off tank to become compliant.
Funding that would require a further bank borrowings, as reducing cow numbers would not cover the current financial liabilities.
Meanwhile, union bosses have condemned the proposals as ‘excessively blunt and ill-thought-out’.
Dumfries and Galloway regional chairman Colin Ferguson said: “NFU Scotland fully supports policies and practices that aim to reduce emissions and diffuse pollution associated with agricultural activity and believes all farm businesses can and should play their part in meeting climate change challenges and safeguarding water quality.
“There are no excuses for bad practice in this area, but a policy balance of regulation, support and advice must be struck.
“However, responses from our membership clearly show that, if unchanged or unsupported, these proposals bring a costly over-reliance on regulatory compliance that is highly unlikely to yield the desired policy outcomes. Instead, they may lead to very damaging unintended consequences of people leaving the industry.”
He called on the government to recognise the potentially huge impact of their scheme and added: “The case studies show that Scottish Government’s anticipated benefits of reduced emissions and improved water quality are likely to be relatively insignificant and dwarfed by the negative financial impacts on a significant number of agricultural businesses.
“That has economic implications for Scottish agriculture, Scotland’s rural economy and the wider supply chain.
“If Scottish Government is to pursue this, then a proportionate and enabling regulation is required, as well as effective financial support. Both are needed to deliver the desired environmental outcomes without excessive, punitive or business threatening costs to individual farm businesses.”