Environmental permitting is a regulatory process that sets minimum standards for operations that aim to reduce pollution and potential risk in terms of air, water and land.
These cover nutrition, housing systems, slurry management and the control of and monitoring of emissions.
Both the pig and poultry sectors are required to obtain environmental permits; for poultry this is required for above 40,000 places and for pigs this applies to numbers over 2000 places over 30kgs for production and 750 places for sows.
Extending regulations to cattle
The government published its Water White Paper in January of this year which it has called a ‘once in a generation’ plan to reform the water system.
Within this the government has renewed its ambition to extend permitting to the cattle sectors, which refers to both dairy and ‘intensive beef.’
The NFU continues to raise concerns over these proposals and the cost and burden they will place on producers. We are working closely with Defra's air and water quality teams, the (EA Environment Agency) and wider industry stakeholders to ensure any future regulations works alongside productive, profitable businesses.
Unfeasible regime
For dairy cattle in particular, it is clear both Defra and the EA have a strong ambition to extend environmental permitting to the sector with the stated aim of reducing pollution rates, improving air and water quality, raising compliance levels and helping to meet legally binding air quality targets.
The industry has been very clear that it does not support the extension of environmental permitting as it is currently administered in the pig and poultry sectors, to the cattle sector.
The diverse range of production systems, extensive grazing periods during certain times of the year, the lack of mitigation options for certain businesses plus the cost and paperwork associated with the implementation of a permitting regime makes the proposal to extend environmental permitting as it stands for pigs and poultry to the dairy sector completely unfeasible.
It is vital that we continue to showcase ongoing improvements and continue best practise in relation to both water and air quality to reduce the burden of regulation and demonstrate clear accountability and action.
NFU asks
- Defra to commit to the inclusion of an industry-led option in any future consultation on the extension of environmental permitting regulations.
- A Ministerial-level commitment from Defra and the Environment Agency to work fully alongside the industry to aid the design of an industry-led solution that is outcome-led.
The NFU dairy and livestock teams have put together a set of key policy principles which must sit behind any proposed regulatory option included in a future consultation on extending permitting regulations:
- Industry-led measures should be considered a priority area for development in the interest of regulatory efficiency and effective outcomes.
- Different cattle sectors and systems have different interactions with the water and air environments. Effort must be made to understand these differences, which will both inform the risk profile at a sector, system and individual level, and influence mitigation approaches.
- Solutions are likely to be multi-faceted and should be crafted in the joint interests of environmental outcome, business viability and food production
- Defra should be clear on the definitions and scope of its terminology eg, permitting, intensive, “high-risk” etc.
- Any proposals should be subject to a credible impact assessment, particularly considering the importance of business growth, food security and meeting both the domestic and global rising demand for protein. Defra needs to set out its evidence for requiring EPR for the cattle sectors.
- Environmental permitting should not be treated as income generation for a regulator as this would be considered a tax on food inflation. Any income generated from EPR should be ringfenced.
- Policy should be developed on current and up to date evidence and data from credible sources
- It is vital that financial support for investment in infrastructure on farm to improve and protect air and water quality is in place and accessible.
- Any reduction in emissions must be recognised by the national GHG emission and ammonia emission inventories.
