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4. POSSIBLE DEVELOPMENT OF MEASURES

Diffuse pollution requires an approach different to traditional point source controls. The nature of diffuse pollution is such that controls must be focused on the activities causing the pollution rather than simply regulating pollutant losses at a particular point. A combination of possible measures, encompassing education, economic and regulatory approaches, need to be considered in order to secure the most effective action.

4.1 Source control

While this document is primarily about measures that can or must be applied on farms or in forestry, there may be scope for pollution prevention through action at source. An example is encouraging the use of combined fertilisers that are low in phosphates. Many fields have sufficient phosphate, but more is commonly added by the application of combined fertilisers. Encouraging the use of low or no-P fertilisers could help prevent the process of eutrophication.

Another example would be to make available animal feedstuffs low in or free of phosphates. Such a measure is akin to encouraging households to use detergents and dishwater soaps that are low in phosphates.

SEERAD will consider separately in consultation with other interests in the UK whether any such source control measures can help reduce diffuse pollution.

4.2 Farm Planning

Farm plans are of increasing importance and their use is encouraged under CAP Reform measures introduced by SEERAD. Farmers in NVZs are already required to draw up fertiliser and manure plans to comply with the Action Programmes that apply in those areas. Such plans can be important to combating diffuse pollution as the causes of and the measures to tackle diffuse pollution are often farm-specific.

All farms could be encouraged to develop nutrient, waste and biodiversity management plans as integral parts of their business planning, and this could be a Tier 2 measure in the LMC Menu Scheme. Suitable farm plans should result in changes to farm practice that reduce diffuse pollution, for example ensuring that steading drainage systems separate clean and 'dirty' water.

Consideration should being given to measures to encourage all farms in a particular catchment to work to similarly high standards.

4.3 Farm audits

The 4 Point Plan already gives details of how to conduct a steading dirty water audit (see Annex C). This gives information on how to improve current good practice and ideas on minimising dirty water around the steading.

Farm audits may already be done on a fragmented basis, but there may be scope for the design of an overall farm audit which covers all aspects of the problems of diffuse pollution.

This could take the form of a self regulated audit, following a preset audit trail, containing guidance to identify solutions where the audit detects a lack of compliance. We wish to explore further the options of a farm self audit or advisor based audit and the possibility of funding such ventures.

4.4 Buffer strips/ no spread zones

Buffer strips are currently the subject of several initiatives for the protection of a variety of environmental purposes. The benefits attached to having an uncultivated strip along a watercourse are well understood, and the Executive will continue to support such measures through LMCs. To ensure protection of water quality, however, one proposal could be the introduction of a GBR to require no-spread zones along watercourses, of for example 10 metres for manure and slurry, 5 metres for pesticides and 2 metres for inorganic fertilisers.

Compliance with the Plant Protection Products Directive is due to become a cross compliance requirement as from 1 January 2006. To receive the Single Farm Payment, farmers will have to follow the Code of Practice for the Safe Use of Plant Protection Products in Scotland, using the pesticide at the correct dosage levels and leaving sufficient 'buffer zones' so that the spray does not enter watercourses.

4.5 Constructed Wetlands

Farm audits have shown that significant contamination can still be associated with steading run-off, even after separation of 'clean' from highly contaminated areas on farm steadings, with slurry draining to closed storage systems for land application. Run-off from farm steadings and areas such as peripheral yards and tracks and areas affected by vehicles, typically contains residual traces of FIOs and other potential pollutants even when good practices are followed. Evidence indicates that a retention pond, wetland or similar for the steading that collects the run-off from the hard standing areas can adequately treat lightly-contaminated dirty water, removing FIOs, lowering BOD, suspended solids, nutrient concentrations and, in addition, can provide a valuable wildlife habitat. Although relatively lightly contaminated, such run-off could be a priority concern as a diffuse source of FIOs with consequences for both fresh water and bathing water quality.

SEPA is currently conducting research as to the efficiency of this approach and will publish guidance in due course. SEERAD will consider the interaction with the SSAFO Regulations.

4.6 Best use of animal manure/slurry

Research has been carried out to explore complementary and alternative treatment strategies for the prevention of water pollution from faecal micro-organisms originating from livestock manures. The study investigated anaerobic digestion, extended storage, oligolysis, lime treatment, pasteurisation, liquid composting and solid composting. Details of this research can be found on the Scottish Executive website http://www.scotland.gov.uk/Resource/Doc/1057/0002224.pdf. As noted earlier, farm-scale trials of biogas and composting are underway currently and a report is due in autumn 2005.

Guidance on the proper use of manure and slurry may also be found in the PEPFAA Code.

4.7 Pesticides

For the purpose of this document, pesticides include crop protection chemicals such as herbicides, fungicides growth regulators and insecticides. They also include substances, preparations or organisms prepared or used as pesticides to protect plants or wood from harmful organisms or pests. Some of these chemicals may be defined as 'biocides'

All elements of the safe use of pesticides are described in the Code of Practice for the Safe Use of Pesticides on Farms and Holdings which is due to be replaced in 2006 by the Code of Practice for the Safe Use of Plant Protection Products in Scotland. Further guidance is also available in the PEPFAA Code, the Forests and Water Guidelines and Reducing Pesticide Use in Forestry (Forestry Commission Practice Guide).

Although the Code of Practice and the Voluntary Initiative will go some way in encouraging the safe and responsible use of pesticides, there may still exist gaps in operators' knowledge of the toxicity of the product to the water environment. Due to this toxicity, one proposed measure of control is a General Binding Rule based on the handling and use of pesticide. As pesticides are used in areas other than agriculture or forestry, any proposed GBRs will also apply to other sectors handling and using pesticides near watercourses.

4.8 Catchment Planning

In England it is proposed that one supportive measure to reduce diffuse pollution from agriculture should be the appointment of Catchment Officers. They would be available to give advice and to monitor all activities within a specific catchment and promote cooperation between stakeholders. Catchment officers working in priority catchments could implement or coordinate activity to collate information on the problems, priorities and potential solutions.

In Scotland each River Basin Management Plan will be developed in conjunction with the SEPA River Basin Management Planning Team and an Area Advisory Group. The local knowledge of the Area Advisory Group will be vital in the planning of any controls which may be required within the catchment

The Custodians of Change report also identified that: Individual farmers cannot deliver what is required in isolation. Impacts on the environment extend beyond farm boundaries; water (clean or polluted) flows through neighbour's land into rivers that interact with whole communities and birds and other wildlife.

Questions

6. Do you agree with the idea for self-audit/environmental checklist of the farm's environmental practice?

7. We think it is important to help farmers/foresters/land managers understand the likelihood of water pollution from their enterprise. What is most likely to be effective?

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