In a submission to Scottish Government, NFU Scotland has branded some of the proposals for changes to the General Binding Rules (GBRs) as neither risk based, nor proportionate.
The proposed wording of GBR 18 would see a blunt prohibition on spreading organic or inorganic fertiliser on land with an overall gradient in excess of 12 degrees.
The proposed wording of GBR 23 could see a ban on the application or drift of pesticides over ground with a slope of 12 degrees or more leading to surface water, unless there is a ten metre vegetated buffer zone.
Andrew Bauer, Policy Manager for NFU Scotland, said:
"NFU Scotland, SEPA, and others are helping Scottish farmers minimize agricultural diffuse pollution and we remain firmly committed to this effort. However, we as a Union have no choice but to strongly oppose some of the detail of Scottish Government’s proposals.
"A large proportion of Scottish farmland slopes more than 12 degrees, therefore a ban on the use of festilisers and pesticides on this land would have a drastic impact on Scottish agricultural productivity and Scotland’s food security.
"The Scottish Government is proposing to create rules that only take account of the slope of the land, however diffuse pollution risk is also affected by weather, vegetation and application technology amongst many other factors.
"NFU Scotland strongly advocates regulation that takes account of these various factors. Both the NVZ action programme and GAEC provide an easily understood and proportionate way to assess the risk and we would urge the Scottish Government to adopt something similar for the GBRs."
Notes to Editors
Contact Wendy Fleming on 0131 472 4020