NFU submits response to consultation on charge proposals for water discharges

11 March 2024

The Environment Agency launched a consultation on changes to the costs of spreading sheep dip and other materials to land under a water quality permit. The NFU has now submitted its response.

Alongside sheep dip, the EA is also looking to change the application and annual subsistence costs of securing a permit for spreading pesticides, biocides, and disinfectants.

For each of these activities, the application charge is set to rise by 50%, resulting in permits costing £4,063, minor variations costing £1,219, normal variations costing £2,031, and substantial variations costing £3,657.

In addition, the consultation proposes a new charge of £2,035 when a habitats assessment is needed for the above activities and a charge of £1,546 for specific substances assessments for a groundwater activity.

In terms of the annual subsistence charge, there will be a 2% decrease for low volumes of sheep dip, while high volumes of sheep dip will see a 2% increase and any volume of pesticide, biocide, and disinfectant will face a 4% increase.

The EA also plans to increase permit charges for trade effluent, non-sewage effluent discharge, and rainfall-related discharges, though application fees for small sewage discharge applications from a domestic household will not change.

At this stage, the NFU is particularly concerned about the planned 50% increase to the application fee for a sheep dip spreading permit, given the poor performance of alternative treatments for scab and the short supply of contracting services.

11 March 2024

Consultation closes

This consultation has now closed.

11 March 2024

NFU submits response

Having carefully considered the consultation documents, and thoroughly discussed them with our membership, we must strongly disagree with many of the proposals.

Our position on each proposal relevant to our members is set out in our response together with our reasons for taking our position.

Cost increase ‘unaffordable’

It is not possible for the NFU to fully comment on the validity of the proposed changes in both annual subsistence fees and application fees, as the EA refuses to apportion them to specific costs. The onus is solely on the EA to demonstrate greater transparency and show that these costs are fair, proportionate, and competitive. We call on the EA to show that it is efficient in its processes and doing everything it can to keep these costs of these services to a minimum.

What we can say is that, for sheep farmers, the annual fee and application fees are already far too high and any increase – let alone the planned 50-125% increase in application fees – would be completely unaffordable.

In the context of less public funding, greater global competition, potential disease outbreaks, and the EA’s own waste exemptions consultation, we urge the EA to delay the implementation of any charge changes until additional dialogue and solutions for mutual benefit for the EA and industry can be discussed and agreed.

If the EA cannot delay the implementation, we ask it to bring the changes in application charges more in line with those in annual charges and bring forward the resulting changes in increments over several years.

Risk to animal health and welfare

By far the greatest concern around these proposals, particularly arising from conversations with our members, is the potential for unintended consequences for animal health and welfare.

Sheep dip is widely recognised as the most effective way of preventing scab and making this treatment less accessible to farmers by charging high fees for disposal risks wider occurrence of the disease.

NFU members can download our response in full at: NFU responds to charge proposals for water discharges.

29 January 2024

Environment Agency launches consultation on charge proposals for water discharges

The EA is reviewing its permitting and regulatory activity for water quality activities and is seeking views on charge increases for:

permit application charges, including additional charges for habitats assessment
most annual subsistence charges
new annual subsistence charges for permits held by sewerage undertakers operating the public sewerage system and treatment activities
new duties and charges following Environmental Permitting (England and Wales)(Amendment)(England) Regulations 2023 groundwater amendments
new supplementary charges for specific substances assessments (and changes to the circumstances when they are payable).

The deadline for submitting feedback to the NFU has now passed.

You can also submit your views directly to the EA via its consultation page and read the EA's document outlining the impact on businesses from changes to charges for water quality permits.

This page was first published on 16 February 2024. It was updated on 11 March 2024.

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Summary

11 March: Consultation closes and NFU submits its response.
29 January: EA opens consultation, asking for views on proposed changes to charges for permit costs for spreading sheep dip and other materials.