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ploughed, of rivers and streams that would be fenced to exclude livestock, etc. Where
livestock are regularly standing in numbers in a watercourse, perhaps sheltering
where a stream crosses the bottom corner of a field, the impact on water quality can
be severe; a diffuse pollution hotspot. Under the regulations in CAR 2005, a notice
can be served requiring the farmer to carry out measures such as stream fencing and
protection from contaminated field run-off. Similarly pollution can be prevented from
a poorly sited hay-feeder for livestock in a field, to require its relocation to a position
where puddled ground around it will not result in contaminated drainage entering a
watercourse. Use of such provisions to control diffuse pollution hotspots in arable
land might be more difficult to achieve successfully, and it may be better to seek
control by in-field measures specified in a GBR, backed by catchment initiatives and
GAEC measures?
Planning and other management techniques
Nutrient budgets, farm manure and slurry management planning are all recognised
good practice. In NVZs, nutrient budgets and farm waste management plans are
already statutory requirements. Such commonsense approaches to use of resources
and avoidance of unnecessary expense, as recommended in the PEPFAA code,
should be more widespread. There are often significant savings to be made for
the farmers, alongside the environmental opportunities. The smaller the farm units,
the simpler the estimations required. These measures are obvious candidates for
the national statutory measures to meet WFD requirements for controlling diffuse
pollution.
Even-handedness Across Rural Sectors
It is important that an even-handed approach is taken, and seen to be taken, in
regulating pollution risks. That has been achieved in CAR for the regulation of
surface water discharges from the built environment, which includes steadings,
forestry offices and depots, golf courses and everything else that involves buildings,
yards, roads roof areas, etc. Surface water discharges are authorised by GBRs 10
and 11, as noted above and that applies across all sectors in Scotland.
Under the infield measures discussed above, a simple GBR approach for farming
was also outlined, and reference made to the recent consultation by the Scottish
Executive.
A simple GBR approach for forestry would be easy to devise, in direct consultation
with forestry interests and at-risk environmental sectors such as fisheries and nature
conservation interests. Scotland is soon to be a net exporter of timber, with potential
risks to the trophic status of oligotrophic waters, as well as the spawning grounds
of migratory fish.
Cost Recovery Challenges: GBRs, Registrations or Licences?
A subsistence charge could be attached to registrations, and certainly to licences,
to enable SEPA to recover the cost of regulation. For non-registered GBRs, what
are those costs likely to be? Direct funding for SEPA by central government for
activity to manage diffuse pollution is likely to continue to be essential. In Canada,
on the spot fines can be imposed by regulators for minor water pollution offences;
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