Defra released an industry-wide consultation in September after identifying a gap in the regulatory framework which underpins the European Water Framework Directive. The consultation closed last week.
Mark Pope, chairman of the NFU Environment Forum, said: “The proposed catch-all regulatory approach is disproportionate as it takes no consideration of the intensity of farming activity and locations. If a decision to implement the proposed rules is taken the NFU urges that Defra consider an exemption for low intensity holdings.
“The proposed rules also shift the burden of proof for pollution away from the Environment Agency and onto the land manager. This is unjust as the land manager will have to prove pollution has not occurred rather than the EA proving it has. This will add significantly to the already large burden on time pressed farmers.
“Many of the rules are already being carried out by farmers anyway via NVZ and Cross Compliance and other rules are followed by many voluntarily, such as through engagement with Catchment Sensitive Farming, water company catchment management programmes and environmental NGO programmes, as they are best industry practice.
“Our preferred option, and the best way to support the environment, would be to adopt a non-regulatory and advice-led approach.”