The NFU is urging members who use harvested rainwater for crop irrigation to check that their on-site facilities comply with a new regulatory position statement published by the Environment Agency.
The collection, storage and use of rainwater from glasshouse rooves and other structures is common in the horticultural sector. Because the water used is invariably applied to crops by trickle methods of application, abstraction regulations have not historically applied to this activity.
Following the introduction of new regulations to bring a range of ‘New Authorisations’ into the licensing system, exempt operators such as existing trickle irrigators must submit a validated licence application no later than 31 December 2019 to benefit from transitional arrangements. These arrangements apply to all users who can show that they have been abstracting from surface or groundwater sources for the purposes of trickle irrigation during the qualifying period of 2011-17.
Technically, the new licensing requirements apply to all ‘sources of supply’ for the purposes of abstraction regulations and there are a number of cases where reservoirs used for the storage of captured rainwater are considered to be a ‘source of supply’, meaning that an abstraction licence is required.
Furthermore, where the reservoir needs a new licence because it has previously benefitted from the ‘trickle exemption’, the application should be made as soon as possible to ensure that it is validated before the 31 December 2019 deadline (in exactly the same way as applications for trickle irrigation licences from abstracted sources).
Following discussions with the NFU and other organisations within the Water for Food Group, the Environment Agency has now published a position statement and an accompanying set of scenarios to explain how it will treat this complex issue. Both documents should be used by members seeking clarification on how they should act to ensure their own on-site operations are compliant.
The Environment Agency is keen to stress that it promotes rainwater harvesting as a water efficient operation, and seeks to avoid unnecessary regulation where there is no environmental risk.
The Agency’s position statement confirms that where rainwater only is harvested and collected in a reservoir (with or without an overflow), then an abstraction licence is not required.
A lengthy menu of possible rainwater collection and storage options is described in the Agency’s ‘scenario’ document. The NFU hopes that the Agency document will guide members towards the most appropriate action for their own rainwater harvesting arrangements.
Most members will have a choice of applying for an abstraction licence where necessary, or amending their collection and storage facilities on-site to ensure they fall outside the regulations.
There will be some situations, for example where a reservoir is used to store both harvested rainwater and water from abstracted surface water or groundwater sources, where a licence will still be required.