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widely recognised <strong>as</strong> needing much attention in Scotland or indeed much of the<br />
UK; contamination <strong>as</strong>sociated with livestock grazing in fields, with growing crops<br />
in are<strong>as</strong> prone to soil erosion, harvesting timber, movements of livestock, access<br />
to watercourses. There are also strategic decisions to be taken in catchment<br />
management, for example recognition that with or without BMPs, there will be more<br />
P and N loss from a field of potatoes than from a gr<strong>as</strong>s field or cereal crop: the landuse<br />
decision is the first level for managing pollution risks. A general set of rules could<br />
bring in national me<strong>as</strong>ures, but targeting specific high-risk are<strong>as</strong> of fields for soil<br />
erosion control, lengths of watercourses to be fenced off, etc., would be site-specific<br />
control and likely to be licence territory. It may prove best regulated by an alternative<br />
approach, perhaps using supplementary me<strong>as</strong>ures for site-specific circumstances?<br />
Can Regulation be Focused on the Target Are<strong>as</strong> within a Farm?<br />
The following sections consider how a regulatory approach could ensure use of<br />
BMPs to address rural diffuse pollution problems, and follows the BMP system<br />
used in Campbell et al. (2004) and in the new BMPs Manual produced for SEPA and<br />
stakeholder partners by CEH (Centre for Ecology and Hydrology). Four target are<strong>as</strong><br />
are considered: steading, in-field, riparian and planning tools.<br />
Steading controls<br />
Source apportionment studies have shown that steadings (farm buildings, yards<br />
and any other <strong>as</strong>sociated roof and hard standing are<strong>as</strong>) are a significant source of<br />
contamination (Edwards et al. in prep.) The GBRs 10 and 11 in CAR 2005 effectively<br />
provide a statutory b<strong>as</strong>is for managing pollution risks from steading drainage, and also<br />
for surface run-off from other rural developments such <strong>as</strong> forestry offices, housing<br />
and depots, golf course buildings and car parks, and poultry units, piggeries etc. An<br />
additional requirement in a farm GBR could be to require the use of a biobed where<br />
yard run-off at risk from pesticide handling does not drain naturally onto gr<strong>as</strong>sland.<br />
A broad range of controls can be envisaged for managing pollution risks at steadings;<br />
from control at source for high strength, low volume pollution risks (storage and<br />
handling controls) to high volume, relatively low contamination where drainage<br />
infr<strong>as</strong>tructure me<strong>as</strong>ures are needed to attenuate the pollutants, such <strong>as</strong> SUDS and<br />
other BMP drainage features (see Figure 2). Bhamidimarri et al. (in preparation) are<br />
developing design guidance for constructed farm wetlands. The difficulty for steading<br />
drainage from livestock farms in the UK, is at what point on the schematic (what level<br />
of contamination) can dirty water be allowed to drain to a constructed wetland or<br />
onto gr<strong>as</strong>s where no drainage system is used, without risking a contravention of the<br />
Silage Slurry and Agricultural Fuel Oil regulations (SSAFO regulations).<br />
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