皇家华人

This Call for Evidence has now closed for submissions.聽

The Independent Commission鈥檚 call for evidence contained 73 questions that relate to the chapters of the . These are mainly aimed at the water industry but we focussed on chapter 2 as having the most intersection with policy and regulation that relate to farming.

It considers the strategic management of water in England and Wales and the many competing pressures and demands from a range of sectors.

Draft responses to questions in the review been tested with the water leads from the NFU commodity boards and modified from the feedback.

Key questions in the chapter we sought input on were:

Water system outcomes

We gave our top three future priorities for the water system as the following from the list provided:

1. Resilient and reliable supply of water for businesses.
2. Reduced flood risk.
3. Improved water environment (eg, healthy habitats for aquatic plants and animals).

We believe that the outcomes to prioritise from the water system should be decided on a multi-sector basis and consider integrated water management planning over current siloed approaches. These decisions are best made at a local catchment level and on a regional scale, using local decision making structures and local accountability, but that are guided by a national strategy and targets.

Failure to incorporate agriculture in the decision making process about outcomes for the water sector puts at risk other outcomes for the government, such as security of food supply and the economic growth of the sector.

It also limits options that involve the creative use of land to deliver green solutions for the water sector. Land managers and land owners are used to delivering a multi-functional, dynamic space that creates a thriving, profitable farming industry and enables Britain鈥檚 farmers and growers to continue producing more sustainable, affordable homegrown food while carrying out important work in caring for the environment, creating more jobs and supporting greener energy security.

Options for this multi-functional space that deliver co-benefits for water resources, flooding and water quality, such as soil health and management, over large areas of land may be overlooked without land owning and tenant farmers having a stake in the process.

Management of water

To facilitate working across sectors and integrating water management at regional and catchment levels there needs to be board level representation of sectors together with strategic authorities for regional groups, plus better coordination between catchment partnerships and Regional Flood and Coastal Committees with a forum for discussion.

The Commission should consider the vital role that other collaborations can bring and which the agricultural sector can contribute to. We must recognise the range of different catchment level partnerships that service the agricultural sector. This includes Catchment Sensitive Farming, cluster farmer groups, abstractor groups such the Broadland Agricultural Water Abstractor Group, Internal Drainage Boards and initiatives such as Future Fens and the Poole Harbour Agricultural Group, as well as catchment partnerships.

By involving key groups of farmers, the agriculture sector can be involved and invested in leading the way in the development of catchment level improvements. It will also facilitate collaborative working between stakeholders and create a sense of ownership, both of which are more likely to ensure better long term outcomes.

Of the list of barriers we selected the following three:

• Unclear targets and objectives.
• Limitations of understanding of the full set of pressures (eg, which sector is responsible for a pollution source).
• Limitations of alignment of existing funding pots (eg, water company investment, agri-environment schemes, government funding for Catchment Partnerships).

Management of the water environment

There should be a review of the Water Framework Directive Regulations 鈥榦ne-out, all out鈥� rule for Good Ecological Status. Often, a river is reported as not achieving 鈥榞ood status鈥� even where all but one of the many contributing indicators do meet 鈥榞ood status鈥�. We believe that this rule gives a misleading impression of water quality and hides a lot of the progress being made.

Our departure from the EU gives us the opportunity to re-look at the metrics laid down in the WFD about how we assess and measure water body status. We should be looking at how much we learn from a system based on the one-out-all-out rule for calculating status based on elemental measures, and review the elements themselves and how they are measured. A specific aspect requiring scrutiny is the extent to which data is based on real-world surveying and monitoring versus implied analysis.

We are concerned that progressive cuts to the EA monitoring programme will mean that the amount of real-world data within the system is likely to be at a critically low level for the figures to be meaningful for many stretches of waterbody. The data should be presented in a way that makes it easier to understand what the critical elements are for each waterbody stretch and where those elements can affect real change.

Strategic direction for the water industry

The government should set national targets for the water industry and the overarching framework in which it operates. These should ensure that it integrates within multi-sector planning and supports the delivery of cross-cutting policy priorities including food security at regional and local levels.

For example, the commitment made in the consultation on the Land Use Framework to maintain food security at a time of global uncertainty and supporting farmers and landowners to invest in the long-term viability of their businesses, contribute to that food security and increase their resilience to climate change is only possible if there is secure access to water for livestock and crop production.

Specifically, we are asking for:

• Strategic direction from the government to the water industry to include a food impact assessment that will support the commitments made for the Land Use Framework to maintain food security.
• Access to water for livestock and crop production in times of shortages to be secured through planning policies that support on-farm water storage, investment in water-use efficiency on farm, and innovation in more water efficient crops and farming systems.
• The value of access to water to be recognised in any future food strategy.
• Government to provide support for agricultural water resource planning, to ensure fair access to water alongside public water supply and other sectors in regional water resource planning groups.
• The Environment Agency to commit to timely communication and engagement with abstraction licence holders as they pursue abstraction reform programmes, and to demonstrate a transparent and fair process for any changes proposed.

Current strategic direction is largely limited to household customers and environmental targets without support or direction for water use that delivers wider benefits.

Providing a resilient and reliable supply of water for businesses supporting economic growth, for example, has not been given sufficient weighting in the directions given to the water industry.

Neither have cross cutting policy priorities such as food security or flood storage.

We think the changes that would help water companies to use planning frameworks more effectively to fulfil their duties and deliver their functions include:

• All drainage and sewage systems need to accommodate new development and cope with existing development pressure, plus additional pressures being created by climate change. Poor infrastructure and drainage capacity means new developments are currently increasing the risk of flooding on farmland, as excess water in the system has nowhere else to go 鈥� new development should as a default contain surface water run-off on site, rather than rely on neighbouring land and watercourses to cope.
• Schedule 3 of the Flood and Water Management Act 2010 must be implemented without further delay.
• Implementing Schedule 3 would end the automatic right to connect and would require local authorities or water companies to adopt and maintain systems, rather than the onus falling onto the land manager. All construction work which has 鈥渄rainage implications鈥� would need approval from the local authority before connecting to the public sewer. The implementation would also likely encourage largescale uptake of SuDs (Sustainable Drainage Systems) and other nature-based solutions for flood risk management.鈥疻e need to see this implemented, and local authorities supported with implementation and enforcement.鈥�

皇家华人contributed to the Independent Commission through participation in two roundtable events set up by Sir Jon Cunliffe and has been consulted by regional water resource planning groups and the National Framework for water resources on their submissions.

The Commission, established by the new government last year, is looking at the sector鈥檚 regulatory framework and will make recommendations for reform.

While its work is mostly focused on water companies, the Commission will also be looking at governance issues that stand to impact agriculture.

This sets out the issues identified so far as well as potential areas for change which the Commission wishes to explore.

The Commission has said it aims to deliver a 鈥渁n ambitious, long-term approach to resetting the water sector, in a new partnership between government, regulators, water companies, customers, investors and all those who enjoy our waters and work to protect our environment鈥�.

Questions around water governance

NFU Vice President Rachel Hallos welcomed the launch of the call for evidence: 鈥淲e will now take the time to consider the documents shared thoroughly before responding.

鈥淲ater is an incredibly important issue for our members, be it resources, flooding, or quality, and this engagement provides an excellent opportunity for us to raise concerns and solutions.

鈥淎nd, while the Commission is focused on the water industry, there are questions around water governance which could have a significant impact on agriculture and farm businesses.鈥�

皇家华人will now begin to pull together its own evidence, in consultation with members, and submit a response by the closing date of 23 April.