The stark condemnation came from NFU Scotland after hundreds of the country’s farmers responded to its survey on the new proposals, highlighting what the union termed the ‘potentially damaging costs’ while yielding only unknown benefits.
More than 540 producers across Scotland – looking after 140,000 cows and 17,000 pigs - responded to the union survey, allowing case studies from all parts of the nation to be included in the official response identifying the costs associated with the proposals.
Commenting on its response, president Martin Kennedy said the union supported practices to reduce emissions and diffuse pollution and agreed that all farm businesses should play their part in meeting climate change challenges and safeguarding water quality.
“There are no excuses for bad practice in this area - but a policy balance of regulation, support and advice must be struck,” said Kennedy.
“However, responses from our membership clearly show that if unchanged or unsupported, these proposals bring a costly over reliance on regulatory compliance that is highly unlikely to yield the desired policy outcomes.
“Instead, they may lead to very damaging unintended consequences of people leaving the industry.”
He said the survey made it clear that what was on the table would add additional costs to businesses and added farmers would be unable to recover these from the marketplace, which meant putting Scottish producers at a competitive disadvantage.
Kennedy also said that the case studies drawn together by the union showed the government’s anticipated benefits of reduced emissions and improved water quality were likely to be relatively insignificant and dwarfed by the negative financial impacts on a significant number of agricultural businesses.
The union said the damaging costs with no clear route for businesses to recoup would create collateral damage in some parts of rural Scotland likely to outweigh any benefits the proposals might bring.
With no impact assessment undertaken by the Scottish government Kennedy added: “The consultation included scant recognition and no comprehension of the potential financial costs for affected businesses or key sectors.”
Stressing that farmers’ commitment to environmental issues was unquestionable he warned, however, that a ‘proportionate and enabling’ regulation’ along with effective financial support were required.
“Both are needed to deliver the desired environmental outcomes without excessive, punitive or business threatening costs to individual farm businesses. Public goods should not be met by private costs.”
Key among the proposals would be the effective extension of NVZ calculations across the whole of Scotland, storage to be boosted to cope with the wettest winter expected over a five-year period and the loss of existing ‘Grandfather Rights’ for any storage built before 1991.