The implementation of European rules requires an overhaul according to NFU
Scotland. NFUS is proposing a new model to put common sense back at the heart
of government’s approach to European regulation.
With the increasing burden of government regulation threatening to damage
the viability of family farms, NFUS believes it is time to address the current
approach to implementation which can be more strict than in other EU countries
whilst delivering little additional public benefit. NFUS is stressing that
the positive aspects of farming must be encouraged, rather than the authorities
seeking to restrict agricultural activity.
Recent government plans to implement EU Directives have flown in the face
of common sense, according to NFUS. The latest moves include implementing
part of a Directive which will actually encourage companies to turn their
back on a clean, renewable fuel and switch to using highly polluting heavy
oil*. Another set of proposals would classify field stones as ‘commercial
waste’, requiring farmers to use a licensed landfill site for disposal**.
NFUS President John Kinnaird said:
“We need sensible regulation, based on sound science, which protects
our environment and ensures the highest standards of animal welfare and food
safety. That delivers clear benefits to farmers as well as consumers.
“In Scotland, Land Management Contracts are a vehicle to support the
huge amount of work that Scottish farms undertake to protect the environment
and strengthen our animal health status. There is far more we could do, in
particular to fight climate change through the development of renewable fuels.
“However, despite assurances that goldplating will be avoided, government
still seems to have a ‘regulate first, ask questions later’ policy
of dealing with EU Regulations. As a result, we are faced with often ludicrous
restrictions, which are completely unnecessary and deliver very little for
the environment or public. The EU Regulations and Directives facing Scottish
farms are often aimed at problems which are insignificant in this country.
“For example, everyone agrees with the principle of protecting our
water quality, but imposing huge costs onto farms for using water where it
is plentiful and where there are no quality problems is ludicrous. Likewise,
it seems madness to ask vehicles transporting livestock to install heating
systems to ensure temperatures are above 5 degrees when we have hardy livestock
that are able to spend most of their winters outdoors with no health problems.
“We propose a new model which would bring trust back to the regulatory
process. If there is going to be new regulation, evidence must be presented
to justify it, a cost/benefit analysis on charges is essential and the whole
process must be transparent. Sadly, that is all lacking at the moment.”
NFUS is proposing a six-stage process for determining how new EU laws are
implemented in Scotland:
Step 1 - Determine if EU Regulation/Directive is relevant to Scotland.
Step 2 - Present evidence to justify the conclusion, in particular where
problems vary in different areas of the country.
Step 3 - Determine if there is an alternative to regulation i.e. information
campaigns/voluntary codes/incentive-based schemes - and consult with
stakeholders to determine approach.
Step 4 - If regulation is the best option, target it at priority areas.
Step 5 - Do a full cost-benefit analysis, open to public scrutiny,
prior to implementation.
Step 6 - Ensure charges are transparent, with a full breakdown of costs.
Charges must be benchmarked against other areas of UK and EU.
An inquiry into the implementation of EU Directives is currently being undertaken
by Jim Wallace MSP on behalf of the Scottish Parliament’s European
and External Relations Committee. NFUS has submitted its evidence, a copy
of which is available on request.
- *The Waste Incineration Directive (WID), which came into force at the
end of 2005, aims to limit harmful emissions from the incineration of waste.
However, the wording of the Directive means that tallow (rendered animal
fat) is also defined as waste, despite it being used by the rendering industry
as a renewable fuel (it is used in steam-raising boilers to power the rendering
process). The rendering process has never been associated with the risks
the Directive seeks to minimise. To comply with WID, plants would have
to install costly equipment that few have the space for. As a result, unless
this problem is addressed, this environmental Directive would force plants
to revert to burning heavy fuel oil rather than a green, renewable fuel.
Up to 22 member states have said that tallow can still be burnt, the UK
Government has not.
- **The EU Landfill Directive aims to ensure responsible
disposal of waste. However, proposals currently out to consultation mean
that field stones would be defined as ‘commercial waste’. As
a result, farmers would ultimately have to dispose of them in a licensed
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